Natural Gas Safety Regulatory Framework Safety Case Guidelines

Natural Gas Safety Regulatory Framework Safety Case Guidelines
Decision
CER/07/226 17th December 2007
Introduction
These Safety Case Guidelines have been prepared to assist gas undertakings in the development of their respective gas safety cases for submission to the Commission for Energy Regulation in accordance with the Commissions high level implementation time table (ref: CER/07/174). This implementation timetable requires that gas undertakings submit their gas safety cases for review and assessment by the following dates: Transmission, Distribution and Shipper & Supplier undertakings by 28th March 20081; and Marathon Oil Ireland Limited Interim Gas Safety Case for gas storage by 30th September 2008. The Commission will shortly be writing to the various gas undertakings to request details of their safety case development plans and timelines. This is to provide a level of assurance to the Commission that safety cases will be submitted in accordance with the high level implementation timetable referenced above. With respect to natural gas sites that fall under the safety requirements of the Seveso II Regulations and S.I. 74 of 2006, in particular the proposed Shannon LNG facility, it is recognised that there is significant overlap between the requirements for the LNG Safety Cases as required by the Commission as safety regulator under the Energy (Miscellaneous Provisions) Act 2006 and the Pre-Operating Safety Report required by the HSA as the Central Competent Authority under the Seveso II Regulations and S.I. 74 of 2006. With this in mind, the Commission has held initial discussions with the Health and Safety Authority with the objective of agreeing an approach to the safety regulation of natural gas Seveso sites, such as LNG and onshore storage, that minimises the level of duplication of safety reporting by undertakings, whilst respecting the legislative responsibilities of both the Commission and the HSA. Therefore, the Commission will not publish the LNG Guidelines as part of the Safety Case Guidelines main document until such time as a joint approach to the safety regulation of natural gas Seveso sites is developed between the Commission and the HSA. There are other safety overlaps between the Commission and the HSA, notably the requirements of the Energy (Miscellaneous Provisions) Act 2006 and the Safety, Health and Welfare (Offshore Installations) Act 1987 respectively. In addition, the Petroleum Exploration and Extraction (Safety) Bill will place new responsibilities on the Commission for offshore operations with respect to safety. The Commission and the HSA are in the process of: (i) identifying these potential overlaps through joint discussion; and (ii) developing an approach to the safety regulation of the Kinsale offshore gas storage facility that will minimise the need for duplicated safety reporting and/or overlapping safety regulation. The Storage Guidelines are published as part of the Safety Case Guidelines main document to assist Marathon Oil in the development of its Interim Safety Case and the Commission will
1 The published document Natural Gas Safety Regulatory Framework High Level Implementation Timetable (CER/07/174) showed a submission date of 28th February 2008 for the Transmission, Distribution and Shipper & Supplier safety cases. This is an error and the required submission date is 28th March 2008.
continue to hold discussions with Marathon Oil on matters relating to safety regulation of the Kinsale gas storage facility. There are no currently identified significant safety regulatory overlaps between the Commission and the HSA with regard to Transmission, Distribution and Shipper & Supplier undertakings that would inhibit the development of their respective safety cases although both the Commission and the HSA are committed to ongoing dialogue with respect to the safety regulation of these undertakings, primarily in relation to the investigation of gas related incidents. The Safety Case Assessment Manual, which will be used to assess undertakings submitted safety cases against objective criteria and this will be published for industry comment during January 2008. This will allow an opportunity for undertakings to have early sight of the Safety Case Assessment Manual prior to the submission of their respective safety cases. An important point of note is that the full implementation of the natural gas safety regulatory framework will involve several further stages including the development of safety key performance indicators, licence modification, implementation of governance arrangements, safety reporting formats and legal review. Additionally, the safety framework is subject to a process of continual review and improvement, which will inevitably result in changes to the Safety Case Guidelines over time. With this in mind, the Commission proposes to develop a formal change control procedure for the Guidelines that will allow undertakings to provide input and feedback on the proposed changes. It is anticipated that the formal change control procedure will be available for industry comment and review during January 2008.
Table of Contents
PART A GENERAL REQUIREMENTS FOR GAS UNDERTAKINGS SAFETY CASES..................................................................................... 1 A.1 Introduction ....................................................................................1 A.2 Safety Case Contents.......................................................................2 A.2.1 Facility Description .................................................................... 2 A.2.2 Formal Safety Risk Assessment ................................................ 3 A.2.3 Safety Management System ...................................................... 3 A.2.4 Emergency Procedures............................................................... 4 A.3 Safety Case Reporting Framework ...................................................6 A.4 Safety Case Assessment ..................................................................7 A.5 Safety Case Submission Process ......................................................9 A.6 Safety Case Modifications ..............................................................10 A.6.1 Material Changes..................................................................... 10 A.6.2 Safety Case Modifications Process .......................................... 11 A.6.3 Recording Changes and Modifications..................................... 12 PART B SPECIFIC REQUIREMENTS FOR LNG UNDERTAKINGS......... 14
PART C SPECIFIC REQUIREMENTS FOR GAS STORAGE UNDERTAKINGS ................................................................................. 16 C.0 Executive Summary.......................................................................17 C.1 Introduction ..................................................................................18 C.2 Facility Description........................................................................19 C.3 Formal Safety Risk Assessment .....................................................22 C.3.1 Hazard and Risk Identification and Assessment .................... 22 C.3.2 Recording of Risks ................................................................... 22 C.3.3 Monitoring and Review of Hazards and Risks ........................ 23 C.4 Safety Management System ...........................................................24 C.4.1 Safety Management Policy....................................................... 24 C.4.2 Technical Standards ................................................................ 24 C.4.3 Asset Lifecycle Safety .............................................................. 24 C.4.4 Related Systems and Facilities................................................ 27 C.4.5 Management of Contractors ..................................................... 27 C.4.6 Human Factors ........................................................................ 28 C.4.7 Consultation, Communication and Cooperation....................... 29 C.4.8 Documentation, Data and Records Management..................... 29 C.4.9 Change Management ............................................................... 30 C.4.10 Accident and Incident Investigation......................................... 30 C.4.11 Safety Reporting ...................................................................... 30 C.4.12 Audit and Inspection................................................................ 31 C.4.13 Performance Monitoring and Review ....................................... 31 C.4.14 Continual Improvement............................................................ 32 C.5 Emergency Procedures ..................................................................33 C.5.1 Gas Quality Incidents .............................................................. 34 C.5.2 Specific Requirements for Lower Tier Facilities........................ 34
PART D SPECIFIC REQUIREMENTS FOR GAS TRANSMISSION UNDERTAKINGS ................................................................................. 36 D.0 Executive Summary.......................................................................37 D.1. Introduction ..................................................................................38 D.2 Facility Description........................................................................39 D.3 Formal Safety Risk Assessment .....................................................41 D.3.1 Hazard and Risk Identification and Assessment .................... 41 D.3.2 Recording of Risks ................................................................... 41 D.3.3 Monitoring and Review of Hazards and Risks ........................ 42 D.4 Safety Management System ...........................................................43 D.4.1 Safety Management Policy....................................................... 43 D.4.2 Technical Standards ................................................................ 43 D.4.3 Asset Lifecycle Safety .............................................................. 43 D.4.4 New Connections ..................................................................... 46 D.4.5 Connected Systems.................................................................. 46 D.4.6 Procurement ............................................................................. 47 D.4.7 Human Factors ........................................................................ 47 D.4.8 Consultation, Communication and Cooperation....................... 48 D.4.9 Documentation, Data and Records Management..................... 48 D.4.10 Change Management ............................................................... 49 D.4.11 Accident and Incident Investigation......................................... 49 D.4.12 Gas Safety Promotion and Public Awareness.......................... 49 D.4.13 Safety Reporting ...................................................................... 50 D.4.14 Audit and Inspection................................................................ 50 D.4.15 Performance Monitoring and Review ....................................... 51 D.4.16 Continual Improvement............................................................ 51 D.5 Emergency Procedures ..................................................................52 D.5.1 Gas Quality Incidents .............................................................. 53 Part E SPECIFIC REQUIREMENTS FOR GAS DISTRIBUTION UNDERTAKINGS ................................................................................. 55 E.0 Executive Summary.......................................................................56 E.1. Introduction ..................................................................................57 E.2 Facility Description........................................................................58 E.3 Formal Safety Risk Assessment .....................................................59 E.3.1 Hazard and Risk Identification and Assessment .................... 59 E.3.2 Recording of Risks ................................................................... 59 E.3.3 Monitoring and Review of Hazards and Risks ........................ 60 E.4 Safety Management System ...........................................................61 E.4.1 Safety Management Policy....................................................... 61 E.4.2 Technical Standards ................................................................ 61 E.4.3 Asset Lifecycle Safety .............................................................. 61 E.4.4 New Connections and Re-connections ..................................... 64 E.4.5 Connected Systems.................................................................. 64 E.4.6 Procurement ............................................................................. 65 E.4.7 Human Factors ........................................................................ 65 E.4.8 Consultation, Communication and Cooperation....................... 66 E.4.9 Documentation, Data and Records Management..................... 66 E.4.10 Change Management ............................................................... 67 E.4.11 Accident and Incident Investigation......................................... 67 E.4.12 Gas Safety Promotion and Public Awareness.......................... 67
E.4.13 E.4.14 E.4.15 E.4.16
Safety Reporting ...................................................................... 68 Audit and Inspection................................................................ 68 Performance Monitoring and Review ....................................... 68 Continual Improvement............................................................ 69
E.5 Emergency Procedures ..................................................................70 E.5.1 Gas Quality Incidents .............................................................. 71 PART F SPECIFIC REQUIREMENTS FOR GAS SUPPLY & SHIPPER UNDERTAKINGS ................................................................................. 73 F.0 Executive Summary.......................................................................74 F.1 Introduction ..................................................................................75 F.2 Facility Description........................................................................76 F.3 Formal Safety Risk Assessment .....................................................78 F.3.1 Hazard and Risk Identification and Assessment .................... 78 F.3.2 Recording of Risks ................................................................... 78 F.3.3 Monitoring and Review of Hazards and Risks ........................ 79 F.4 Safety Management System ...........................................................80 F.4.1 Safety Management Policy....................................................... 80 F.4.2 Technical Standards ................................................................ 80 F.4.3 Procurement ............................................................................. 80 F.4.4 Human Factors ........................................................................ 81 F.4.5 Communication ........................................................................ 81 F.4.6 Change Management ............................................................... 81 F.4.7 Customer Gas Safety Awareness ............................................ 82 F.4.8 Safety Reporting ...................................................................... 82 F.4.9 Audit and Inspection................................................................ 83 F.4.10 Performance Monitoring and Review ....................................... 83 F.4.11 Continual Improvement............................................................ 83 F.5 Emergency Procedures ..................................................................84 F.5.1 Gas Quality Incidents .............................................................. 85 F.6. Requirements For Shipper-Only Undertakings...............................86
APPENDIX 1 - TECHNICAL STANDARDS ............................................. 87 APPENDIX 2 SUGGESTED KEY PERFORMANCE INDICATORS .......... 93 APPENDIX 3 - REQUIREMENTS FOR DEMONSTRATIONS.................... 95
PART A: GENERAL REQUIREMENTS UNDERTAKINGS SAFETY CASE FOR GAS
Part A General Requirements for Gas Undertakings Safety Cases
PART A GENERAL REQUIREMENTS FOR GAS UNDERTAKINGS SAFETY CASES A.1 Introduction
These Safety Case Guidelines (the Guidelines) provide guidance to gas undertakings for the development of a safety case as required by the Commission for Energy Regulation (the Commission) under powers conferred on it by the Energy (Miscellaneous Provisions) Act 2006 (the 2006 Act). Although the Guidelines are advisory only, gas undertakings will be required to have regard to the contents in developing their safety case. The Guidelines describe the key aspects of gas safety to be addressed by undertakings in the preparation of a safety case with respect to the storage, transmission, distribution and supply & shipping of natural gas within Ireland. The focus of the safety case is on the safe management of the storage and flow of gas and the response to emergencies. In particular this relates to the management of the safety risks associated with the design, construction, operation, maintenance, and modification/refurbishment and de-commissioning of gas infrastructure. It is not the Commissions intention that the safety case should address in any detail, occupational health and safety or environmental issues as these areas are the responsibility of the Health and Safety Authority (the HSA) and the Environmental Protection Agency (the EPA). Clearly, there are important person-specific safety issues and potential adverse environmental impacts that will need to be addressed in the safety case, however, it is not the intention that the safety case will contain extensive information on undertakings occupational health, safety and environmental management systems.
A.2
Safety Case Contents

The structure of the safety case is generic in nature for all gas undertakings that are involved in the storage, transmission, distribution, supply and shipping of natural gas. The following is an outline description of the key sections of the safety case:
A.2.1
Facility Description A Facility Description that describes the nature, activities, location, organisation structure, safety related responsibilities and gas infrastructure assets (where applicable) employed in carrying out the day-to-day business of the gas undertaking. The Facility Description must provide sufficient information to enable the extent and scope of the assets and operations of the gas company in relation to the facility and the risks associated with those assets and operations to be assessed. These include: location(s) of the companys premises; name of the person who has overall managerial control of the facility, normally the CEO or MD; name of the Duty Holder with respect to the safety case. The Duty Holder will be a person who is a representative of the System Operator of the undertakings facility i.e. the person who represents the controlling mind with regard to the day-to-day operating decisions that are taken; name of the person who is responsible for the preparation and submission of the safety case; management organisational structure with key responsibilities for gas safety and other safety-related interfaces; details of personnel with key gas operational responsibilities and a description of how gas technical safety competencies are resourced; description of the gas-related activities of the business and a description of the assets that are employed in carrying out the activities of the gas undertaking e.g. LNG importation and storage, gas storage, transmission, distribution, shipping & supply. It should be noted that non-gas asset businesses such as shipping and supply should describe the categories and numbers of customers that they actively retail gas to e.g. LDM, DM and NDM customer groups.
The Facility Description must provide sufficient information to enable the extent and scope of the assets and operations of the natural gas undertaking in relation to the facility and the associated risks to be assessed. A.2.2 Formal Safety Risk Assessment A Formal Safety Risk Assessment that is consistent with the activities described in the Facility Description and is based on a detailed and systematic assessment of risk, including the likelihood and consequence of a gas safety related incident occurring and a description of the mitigation measures adopted to ensure that identified risks are maintained at a level that is as low as reasonably practicable. The risk assessment process should take into account the safety risks inherent at each of the stages of design, construction, operation, maintenance, modification and decommissioning of gas infrastructure assets. It is not the intention of the Commission to be prescriptive on the approach to risk management as many businesses will already operate within the context of recognised risk management frameworks. However, an important requirement of the Formal Safety Risk Assessment is that identified safety risks are mitigated to a level that is as low as reasonably practicable (ALARP). The Formal Safety Risk Assessment for a facility should provide: a description of the methodology used and investigations undertaken for the Formal Safety Risk Assessment; an identification of all hazards and initiating events having the potential to cause a gas incident; a detailed and systematic assessment of risk, including the likelihood and consequence of a gas incident; a description of technical and other measures undertaken, or to be taken, to reduce that risk to a level that is ALARP; and Copies of any reports arising from the studies and investigations undertaken for the purposes of the Formal Safety Risk Assessment.
It should be noted that the Commissions judgments on whether risks are being managed to a level that is as low as reasonably will be based on a combination of factors. There is no general interpretation of what constitutes right or wrong in this sense as what is tolerable for one safety risk will be different to what is considered tolerable for a different safety risk. If necessary, the Commission will discuss its interpretation of ALARP with individual undertakings on a case by case basis.. A.2.3 Safety Management System The Safety Management System that the gas undertaking employs to effectively manage the safety risks as identified in the Formal Safety Risk Assessment i.e. the safety policy, organisation, planning, implementing,
audit and performance monitoring and reviewing systems used by the gas undertaking to manage their business-specific safety risks to an acceptable level and ensure that there is a process for continual improvement in place. The Safety Management System should also address the human factors (competencies and capabilities) of staff and contractors that are important in managing and controlling the safety hazards and risks that are identified in the Formal Safety Risk Assessment. The Safety Management System should address the safety risks identified in the Formal Safety Risk Assessment in a manner that reduces all identified risks to a level that is as low as reasonably practicable (ALARP). The Safety Management System should contain a list of all relevant Irish, European and international codes, standards, recommendations and specifications (referred to collectively as authoritative best practice) that are used by the undertaking for the design, construction and operation, modification and maintenance of infrastructure assets. It is important that the undertaking has a system for assuring itself that the technical standards and specifications currently being used are the latest version. As such, the Safety Management System should describe the process for ensuring that all amendments and new editions are recorded and an up to date list of standards is maintained and published. A list of Irish publications for the gas industry, as recommended by the Gas Technical Standards Committee (the GTSC) of the National Standards Authority of Ireland (the NSAI) is included as Appendix 1 for reference. A.2.4 Emergency Procedures The Emergency Procedures should provide details of the emergency response arrangements that gas undertakings have in place in order to provide an effective and coordinated response to larger scale network gas related incidents and emergency situations. The Network Emergency Manager (NEM) Framework is the critically important feature of the various undertakings Emergency Procedures, which should describe in detail how resources and staff with the necessary skills and competencies are arranged to provide a coordinated response to the requests and instructions of the NEM during the various stages of gas supply emergencies, namely: Step Step Step Step Step 1: 2: 3: 4: 5: Potential Emergency Emergency Declaration Firm Load Shedding Allocation of Gas and Isolation Restoration
These arrangements should include a description of: roles and responsibilities of the various Emergency Management team members; arrangements for providing a 24-hour response capability; contact details for staff on an Emergency Rota;
details of the Incident Room arrangements including telephone and fax numbers and e-mail addresses; and arrangements for undertaking in-house arrangements and emergency exercises. testing of emergency
For major accident hazard facilities, the Emergency Procedures should also provide details of the on-site major accident plans that are in place. The operators of major accident hazard facilities will be responsible for managing the response to on-site emergencies themselves and the role of the NEM in these circumstances will be to manage the response to the downstream impacts of such emergency events within the transmission and distribution networks.
A.3
Safety Case Reporting Framework

The safety case regime includes a Safety Reporting Framework that will be used to assess the overall effectiveness and performance of the natural gas safety regulatory framework. Where relevant, undertakings will be required to report on the following basis: (i) Immediate Incident Reporting by gas undertakings to the Commission whereby a gas emergency incident has occurred or there has been a gas related injury or fatality and the Commission will be required to undertake an investigation and make a report to the Minister; Quarterly Safety Reporting by gas undertakings to the Commission based on a suite of key safety performance indicators that are specific to the operational activities of the undertaking. These safety performance indicators will be developed within the context of the Safety Case Guidelines and through liaison between the Commission and the individual undertakings; and
(ii)
(iii) An Annual Safety Report to the Commission which should provide a detailed description of the overall safety performance of the undertaking during the year and the actions the actions that the undertaking proposes to undertake to improve gas safety. This will feed into the process whereby the Commission will provide an annual report to the Minister on the gas safety outcomes for the industry and the performance of the natural gas safety regulatory framework. Individual undertakings will need to develop their business-specific safety key performance indicators and liaise with the Commission on the appropriateness of the KPIs for assessing the safety performance of the undertaking. A suggested suite of safety KPIs for all undertakings is included in Appendix II of this document.
A.4
Safety Case Assessment

The Commissions aim in carrying out assessments of submitted safety cases is to satisfy itself that the gas undertakings have made appropriate and sufficient arrangements to ensure that the gas safety risks that arise from the carrying out of the undertakings business activities are reduced and controlled to a level that is as low as reasonably practicable. Safety cases will be assessed according to criteria developed by the Commission to verify that: A sufficiently detailed description of the undertakings organisational arrangements, key safety responsibilities, operational characteristics and the nature and extent of the infrastructure assets are provided such that an assessment of the gas related safety risks can be made; A detailed and systematic assessment of gas related safety risk has been undertaken that is based on the range of activities described in the Facility Description and that the risks are managed to a level that is considered by the Commission to be as low as reasonably practicable; The undertakings safety management systems are adequate to control the gas safety risks that arise from the operations of the gas undertaking and are identified in the Formal Safety Risk Assessment; and In the event that a large-scale gas emergency situation or a major accident arises, the undertakings emergency procedures and arrangements are adequate to provide a coordinated and effective emergency response and restoration of supply.
The purpose of the assessment is to examine the evidence as presented in the safety case and it is the responsibility of the undertaking to demonstrate that suitable safety arrangements are in place and that gas safety risks are being managed and controlled to an acceptable level. The emphasis of the safety case regime is on demonstration by the gas undertaking that acceptable safety arrangements for the management of gas-safety related risks are in place and working effectively. In this context, demonstration involves a higher standard than simply describing the way measures work or are expected to work. There will be a requirement on the undertaking to provide evidence that the measures described in the safety case work in practice and are monitored to ensure that this actually happens. Appendix 3 gives more information on what is meant by demonstration. The Commissions role with respect to the safety case will be to: develop and update the Safety Case Guidelines for providing the safety information requirements within the agreed structure of the safety case utilising a formal change control procedure;
reviewing and assessing submitted safety cases according to established assessment criteria for acceptance or approval of the safety case; monitoring and auditing the activities of undertakings to check for compliance with their safety cases on a programmed basis; and requiring gas undertakings to carry out a full review of the safety case every 3 years to ensure that the safety case remains as a living document within the organisation and fully reflects the current safety operating measures and practices and to report to the Commission on the findings of the review.
Safety cases that have undergone assessment and subsequent acceptance or approval by the Commission will be required to be implemented within a timescale agreed by the Commission and the undertaking. Safety case assessment is not a one-off activity and each undertakings safety case will be subject to an ongoing audit and inspections regime to verify that the arrangements in the safety case are actually operating in practice. A Safety Case Assessment Manual is currently under development and will be published in due course.
A.5
Safety Case Submission Process

There are two stages to the safety case submission and assessment process. Stage 1 Safety Case Registration Process Three hard copies of the Safety Case are to be submitted to the Commission. Upon receipt of the submitted Safety Case, the document is registered, given a unique reference number and a file opened to contain all relevant documents and correspondence. An initial Content Scrutiny is carried out to ensure that the Safety Case document is complete as described in its own contents. Subsequently, an Initial Screen of the document is undertaken to enable: a decision to be made on whether the document is worthy of further assessment; in consideration of the document and its initial screen, the development of an assessment plan, outlining team members, responsibilities and areas for detailed examination.
It is envisaged that Stage 1 of the process should be completed within 10 working days of the date of receipt of the submitted document. Stage 2 Detailed Assessment The detailed assessment of the submitted Safety Case will be undertaken upon completion of the activities outlined in Stage 1. The major objectives are as follows: determine the areas of the submission that are satisfactorily covered and can be accepted; identify areas where further information or clarification is required to enable suitability or otherwise to be determined; discuss and resolve issues with the representative of the gas undertaking; agree areas where improvement is required; compile a report to recommend approval/acceptance or rejection of the safety case; and identify topics for post acceptance inspections; these may include areas of perceived strength or weakness encountered during the assessment process.
It is envisaged that this process should be completed within six weeks of the date of receipt of the submitted document. It is not the intention of the Commission to make publicly available all, or any part, of an undertakings Safety Case. Safety Cases are regarded by the Commission as confidential documents and will be treated as such.
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A.6
A.6.1
Safety Case Modifications

Material Changes An undertakings safety case is regarded by the Commission as a living document within the organisation and should be maintained as up to date in order to reflect what the Commission may regard as material changes. These include: i) Facility Description: changes in ownership and/or operating responsibility; changes in management structure and key safety responsibilities, particularly with respect to the safety case duty holder and the person responsible for the ongoing management of the safety case; significant changes to the capacity, configuration and/or operation of the undertakings gas infrastructure assets, for example: o the commissioning or de-commissioning of a transmission pipeline, pressure reducing installation or storage facility; o increases or decreases in overall system transportation or storage capacity; and o changes to the system control facilities used for the management of pressures and flows within the facility or network of pipes. Formal Safety Risk Assessment: changes in risk levels that are identified via the ongoing assessment of safety risks, which may include: o new or previously unidentified safety risks; and o increases in the level of a previously identified risk. Safety Management System amendments to key safety related policies and procedures; outsourcing of gas safety related functions e.g. emergency response; changes in the responsibilities of key safety staff; and changes in O&M practices. Emergency Procedures changes that are implemented as a result of the outcome of investigations into gas emergency incidents; and changes to major emergency plans and/or the NEM framework.
ii)
iii)
iv)
The above list is not intended to be exhaustive but to provide an indication of changes that would, in the opinion of the Commission, be of sufficient materiality to warrant a modification to the undertakings safety case. It is anticipated that undertakings will liaise closely with the Commission during the development, submission and assessment of their respective safety cases and identify those aspects of the safety case where future proposed changes to the facility description, formal safety risk assessment, safety management system or emergency procedures would be regarded as material and require a safety case modification and re-assessment by the Commission.
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Additionally, undertakings should recognise that the cumulative effect of a series of relatively minor, non-material changes may well result in the need for a safety case modification. As such, all changes in the undertakings operating practices should be considered in the context of the potential impact on the safety case, which has been accepted or approved by the Commission. The Commission intends to work with undertakings in developing an understanding of what may constitute a material or non-material change with the objective that, over time, undertakings will be in a better informed position to make their own judgement within the context of the above. A.6.2 A.6.2.1 Safety Case Modifications Process Material Changes Where proposed changes in the undertakings safety arrangements are regarded by the undertaking as material, the undertaking shall: Inform the Commission of the proposed change and provide: o o the details of the proposed change; and the reasons for the change
Undertake a safety risk impact assessment of the proposed change and submit the results of the safety risk impact assessment to the Commission for review; Modify and update the safety case; Provide the Commission with an updated version of the modified safety case for acceptance/approval; and Implement the change within the agreed timescale.
A.6.2.2
Non-Material Changes For changes that are considered by the undertaking to be relatively minor or non-material, the undertaking shall: Undertake a safety risk impact assessment of the proposed change; Where the level of safety risk resulting from the proposed change remains the same or is lowered, the undertaking shall update its safety case to reflect the change and make a record of the change and the associated risk assessment. There will be no requirement to notify the Commission in this circumstance; and Where the safety risk impact assessment shows that the proposed change increases the level of safety risk, the undertaking shall notify the Commission. The Commission will then liaise with the undertaking in order to determine if the proposed change can be implemented whilst maintaining safety risk at an acceptable level. Alternatively, the Commission may view the proposed change as
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material and the undertaking will follow the process described above for material changes. A.6.3 Recording Changes and Modifications An important requirement with respect to changes in safety arrangements and modifications to safety cases is the need to safety assess all proposed changes prior to implementation and record such risk assessments and changes by updating all relevant documentation, whether held centrally or circulated amongst staff and operatives to provide an audit trail of changes. In this way, there is demonstration that the safety case is maintained as a living document within the undertaking and is evidence that the undertaking is operating in compliance with their safety case.
The following parts of these Guidelines contain specific minimum information requirements for each category of gas undertaking, as follows: Part Part Part Part Part B C D E F LNG Undertakings. Storage Undertakings. Transmission Undertakings. Distribution Undertakings. Supply & Shipper Undertakings.
PART B: SPECIFIC REQUIREMENTS FOR LNG UNDERTAKINGS
Part B Specific Requirements for LNG Undertakings
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PART B SPECIFIC REQUIREMENTS FOR LNG UNDERTAKINGS

As stated in the introduction to this document, With respect to natural gas sites that fall under the safety requirements of the Seveso II Regulations and S.I. 74 of 2006, it is recognised that there is significant overlap between the requirements for the LNG Safety Cases as required by the Commission as safety regulator under the Energy (Miscellaneous Provisions) Act 2006 and the Pre-Operating Safety Report required by the HSA as the Central Competent Authority under the Seveso II Regulations and S.I. 74 of 2006. With this in mind, the Commission has held initial discussions with the Health and Safety Authority with the objective of agreeing an approach to the safety regulation of natural gas Seveso sites that minimises the level of duplication of safety reporting by undertakings, whilst respecting the legislative responsibilities of both the Commission and the HSA. Therefore, the Commission will not publish the LNG Guidelines as part of the Safety Case Guidelines main document until such time as a joint approach to the safety regulation of natural gas Seveso sites is developed between the Commission and the HSA.
PART C: SPECIFIC REQUIREMENTS FOR GAS STORAGE UNDERTAKINGS
Part C Specific Requirements for Gas Storage Undertakings
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PART C SPECIFIC REQUIREMENTS FOR GAS STORAGE UNDERTAKINGS

This section of the Guidelines contains the specific minimum information requirements for the development of the safety case for gas storage undertakings. For the purpose of these Guidelines, a gas storage undertaking is defined as a Facility under the control of an Operator that imports, stores and exports fuel gas in quantities sufficient to be captured by Part 1 of Annex 1 of the Seveso II directive. For natural gas and liquefied extremely flammable gases the relevant quantities are 50 te for lower tier undertakings, and 200 te for top tier undertakings. The requirements for lower and top tier are defined below. These are minimum information requirements and it is the responsibility of the relevant undertaking to provide sufficient information in order to allow the Commission to make an assessment of the adequacy of the safety case. A balance will need to be struck between the material to be included in the safety case and supporting information, which can be cross-referenced and provided on request. As a guiding principle, safety cases should be presented as self-contained documents which: present the main safety arguments clearly and succinctly so that the core principles can be readily understood; and include sufficient detail to establishing a convincing case for the safety arrangements.
The safety case contents should include the following sections.
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C.0
Executive Summary
An Executive Summary, which explains the storage undertakings approach to risk management, describes the generic safety risks that arise from the major accidents associated with gas storage operations, and a description of the structure of the safety case to demonstrate that there are comprehensive safety management systems in place to identify, assess, manage and control the risks associated with the safe management of the storage of gas and the response to emergencies.
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C.1
Introduction
The safety case should commence with an Introduction that provides information on: 1.1 Scope and objectives of the safety case; 1.2 References to license conditions; 1.3 Identification of those person(s) responsible for the preparation and maintenance of the safety case; 1.4 The contact details of the person with whom the Commission will liaise on matters regarding the safety case; and 1.5 A description of the formal change control procedure(s) that will be applied to the safety case.
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C.2
Facility Description
The Facility Description should provide information on the following aspects of the undertakings operation: 2.1. 2.2. 2.3 The name of the person and position who has overall managerial responsibility for the gas storage business; The location of the storage asset; The location of the undertakings headquarters or main office, the location of subsidiary offices and a description of the activities undertaken at each location; The management organisation structure for the gas storage business that describes how the management of process safety is undertaken, who has responsibilities for process safety, the numbers of personnel employed in each department/function and the key safety interfaces with operational staff; A description of the activities undertaken with the gas storage business, how these are organized and the resources employed to manage the operations of the business; A detailed description of all dangerous substances stored or used at the gas storage facility, including normal and worst case process conditions from which a major accident could arise (NOTE: dangerous substances stored in small quantities that cannot cause or contribute to major accidents can be listed separately with an explanation of why they are insignificant). This should include: o a plot plan of sufficient details to show the locations of dangerous substances within the facility; o the behaviour of the dangerous substances during major accidents; o any dangerous substances formed as byproducts from chemical changes during a major accident (e.g. combustion) must also be supplied; o the CAS number and name under IUPAC nomenclature for each dangerous substance; and o physical, chemical, toxicological characteristics and indication of the hazards, both immediate and delayed, for persons and the environment. For the significant dangerous substances, a justification should also be given for the inventories held at the facility i.e. why the inventories cannot be reduced further. 2.7 A description of how gas is stored by the undertaking, including: o gas reception from and delivery to the relevant gas transmission or distribution system(s), including the interfaces to ensure safe operation and emergency shutdown;
2.4
2.5
2.6
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the plant used to introduce gas into storage, including information on safe operating pressure and temperature limits; the storage system(s) used, including maximum inventories and limits on temperature and pressure for safe operation; the plant used to deliver gas back to the transmission or distribution system, including information on safe operating pressure and temperature limits; other processes present on site that involve the storage and use of dangerous substances, outlining the dangerous substances used and the safe operating temperatures, pressures and other relevant process conditions. Examples include methanol storage and recovery and hydrocarbon liquid (condensate) stabilization and storage; a description of methods used for hazardous area classification at the facility and the means to ensure overall compliance with the EC ATEX directive; plant utilities required to maintain safe conditions e.g. electrical power, instrument air, nitrogen, process water and how adequate reliability is achieved; an overall description of facilities for protecting systems against upset conditions such as pressure relief, venting, instrumented protective systems; an overall description of mitigation systems available in the event of a major accident, such as emergency shutdown, fire and gas detection, blast protection and firewater systems; a description of on-site site bunds, drainage systems etc and the control of effluents on site that could cause or contribute to the effects of major accidents off site (e.g. firewater run-off management); a description of communication systems and centres available on site that are relevant to safe operation and dealing with emergencies; a description of security arrangements to prevent third party interference on site; and
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a description of how export gas quality is maintained within agreed or safe limits for supply to the relevant transmission or distribution networks.
Suitable maps, drawings, tables, charts and diagrams should be used to convey information wherever appropriate. In particular, a suitably detailed plot plan showing the locations of dangerous substances needs to be provided. 2.8 Details of neighbouring facilities handling dangerous substances, which could suffer a major accident of their own if one were to occur at the gas storage facility, or vice versa (referred to as domino neighbours). 2.9 Details of environmental features that could cause or contribute to major accidents, such as geographical location, meteorological, geological, hydrographic conditions, aircraft or other traffic movements and, if necessary, features resulting from the history of the location of the facility It should be noted that it is not intended to conflict with, duplicate or overlap with existing legislative environmental requirements and any environmental studies and/or assessments can be referenced separately provided that they have been undertaken to the satisfaction of the relevant environmental regulator.
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C.3
Formal Safety Risk Assessment

The safety case should provide information on the processes adopted to systematically identify and assess all reasonably foreseeable hazards for major accidents involving dangerous substances on site, in order to determine the likelihood and consequence of the actual risks that they present to persons and property at each stage of the asset lifecycle i.e. design, construction, operation, maintenance, modification/refurbishment and de-commissioning. The descriptions should include the methods of any analyses made and details of any assumptions on asset and human performance and reliability. The level of detail required (including with respect to the sophistication of the risk assessment) should be proportional to the nature and complexity of the operations of a gas storage undertaking and hence to the risks being controlled at a level that is as low as reasonably practicable (ALARP).
C.3.1
Hazard and Risk Identification and Assessment With respect to hazard identification, the storage undertaking should identify all significant major hazards that arise from the operation of the whole storage facility, together with the initiating events that could lead to these hazards. The assessment must cover all relevant dangerous substances on site, and all assets, plant and equipment that could cause or contribute to a major accident involving dangerous substances, including storage systems, pipework, process plant and plant areas and utilities. The assessment must also consider the range of outcomes of a particular major accident, from higher frequency, lower consequence outcomes to the rarer but more severe outcomes. An assessment should made of all the identified hazards in order to determine the likelihood and consequences of the risks that may arise. The assessment may be carried out using qualitative and/or quantitative techniques as considered appropriate by the storage undertaking. The results of the hazard and risk assessments should be used to identify and rank major risk contributors. Risk management strategies should include prevention, protection and mitigation activities and risk reduction strategies should be established for all significant risks.
C.3.2
Recording of Risks The results of the hazard and risk identification and assessment process should be recorded in a suitably formatted risk register that record details of: identified hazards and their causes (initiating events); existing safety controls that are used to manage the risk; an assessment of the risk based on the likelihood and consequence of the risk occurring and tolerability of the risk according to the principle of ALARP;
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a description of the measures in place to manage the risks of major accidents, and why they are considered to be sufficient; an examination of additional risk reduction measures examined as part of the demonstration of ALARP, with a rationale for their adoption and rejection; where relevant, a revised assessment of risk based on the implementation of the additional control measures to demonstrate ALARP; and the name of the person who is responsible for the day-to-day management of the risk(s).
C.3.3
Monitoring and Review of Hazards and Risks There should be a description of the processes used to ensure that identified risks are regularly reviewed to ensure that they are still valid, have not altered in terms of likelihood and/or consequence and are not outdated or redundant as a result of changes in organisational or operational circumstances.
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C.4
Safety Management System

The Safety Management System should describe how the Operator of the gas storage undertaking provides for the safe and reliable storage of gas within the gas storage facility for the duration of the lifecycle of these assets. The essential elements of the Safety Management System are outlined below.
C.4.1
Safety Management Policy The Safety Management System should reference the specific Safety Policy documents published by the storage undertaking that set out the safety management objectives with regard to the safe management of the gas storage facility. This section should describe the approach and methodology used to ensure that the gas storage facility is designed, constructed and operated and maintained in a safe manner and how this will be achieved. A particular requirement of the Seveso II Directive is that a Major Accident Prevention Policy (MAPP) is in force at the Facility. The MAPP must be: endorsed by a person within the storage undertaking with sufficient authority to ensure that all commitments within the MAPP are met; current and in force via the Safety Management System; and subject to periodic review to ensure that it is delivering, and will continue to deliver, appropriate performance in terms of control of major accident hazards.
C.4.2
Technical Standards The Safety Management System should contain a list of all relevant Irish, European and other international codes, standards and recommendations (referred to collectively as authoritative best practice) that are used by the gas storage undertaking for the design, construction and operation, modification and maintenance of the storage facility. These should include a list of updated current technical standards and legacy or historical technical standards used for the design and construction of existing assets. It is important that the gas storage undertaking has a system for assuring itself that the technical standards and specifications currently being used are the latest version. As such, the Safety Management System should describe the process for ensuring that all amendments and new editions are recorded and an up to date list of standards is maintained and published.
C.4.3
Asset Lifecycle Safety 4.3.1 Design The Safety Management System should describe in detail the design principles applied to ensure that all identified hazards and risks are eliminated or reduced to a level as low as reasonably practicable during the life cycle of the asset. The design requirements should include both the physical assets and the associated operating systems for the facility.
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4.3.1.1 Design Inputs Key inputs to the design process should include: o a list of identified design hazards and risks; o a statement of the storage facility design policy; o a description of the system design parameters for the storage facility; and o identification of the various codes, standards and recommendations adopted. 4.3.1.2 Design Process Controls Controls over the design process should include a description of: o the policies and procedures used for design of the facility; o the risk mitigating measures adopted; o the systems and tools used for facility design and modeling, including safety studies such as Hazard and Operability (HAZOP) studies, and studies to establish performance standards for safety related equipment; and o the design validation and approval process. 4.3.1.3 Design Outputs The outputs from the design should include: o construction plans and specifications; o performance standards, both in terms of risks and operational performance; and o specific operational procedures required for safe operation. 4.3.2 Construction, Testing & Commissioning and Work Recording The Safety Management System should describe in detail how the Operator manages the processes of facility construction (including modifications), testing and commissioning in accordance with the adopted codes, standards and specifications. The Operator should provide demonstration of the processes for: o ensuring that construction activities are undertaken by staff and/or contractors who possess the requisite qualifications, training, skills & experience and competencies to undertake the work in a safe manner; o assessing and verifying that the construction work undertaken complies with the specifications; o ensuring that post-construction and precommissioning testing is undertaken in a safe and competent manner and is sufficient to prove that the installed asset is suitable for its intended use; o ensuring that assets are commissioned as per an agreed procedure; and o as-built records are submitted, checked for accuracy and completeness and approved prior to being recorded on the undertakings asset database.
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4.3.3
Control of Operations The Safety Management System should describe how safe conditions are made throughout routine and non-routine operation of the facility. Typical means of control include: o risk assessment; o procedure development and management for routine and non-routine operations; and o permit to work system. Facility Maintenance The Safety Management System should describe in detail how the Operator undertakes the operation and maintenance of the storage facility taking into account the particular risks posed by the facility under consideration. This should also extend to the associated systems that are in place to support the operation and maintenance of the facility e.g. drawings, plans, maintenance records, DCS or SCADA systems, permitry etc.
4.3.4
4.3.4.1 Preventative Maintenance, which includes such activities as: o prioritisation of maintenance tasks; o integrity assessment of pressure containing systems such as vessels and pipework; o condition monitoring and maintenance of machinery and other equipment with moving parts; o maintenance and calibration of instrumentation relevant to safe operation; o monitoring for potential settlement or excessive movement of critical structures; o monitoring of cathodic protection systems and other systems relevant to corrosion control; o monitoring of potential leakage from containment systems; o maintenance of safety instrumented systems and other safety related protective or control systems; o non-routine operations procedures; and o permit-to-work systems. 4.3.4.2 Corrective Maintenance, which includes such activities as: o identification, notification and prioritization of items requiring corrective maintenance; o responding to process upsets and breakdowns, including leakage from plant items; and o responding to emergencies. 4.3.4.3 Supporting Systems Maintenance, which includes such activities as: o storing and updating asset records i.e. drawings, plans, databases etc; and o maintenance of DCS or SCADA systems.
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4.3.5
Modification, Replacement and Reinforcement The Safety Management System should describe in detail the processes that the Operator uses for undertaking modifications and other changes relevant to the management of major accidents including the processes for: o o o o o identifying the need for modification; risk assessment of modifications and the setting of performance standards for the modification; developing, designing and selecting the chosen approach to modification; approving the selected design; and updating asset records.
This may be combined with Section 4.10 where appropriate. 4.3.6 De-Commissioning and Abandonment The Safety Management System should describe in detail the processes that the Operator uses for de-commissioning and abandoning the facility including: o identifying the need for de-commissioning and abandonment of an asset; o assessing the impact of the decision to decommission and abandon an asset; and o recording of de-commissioned and abandoned assets on the companys asset database.
C.4.4
Related Systems and Facilities The Safety Management System should describe the interfaces between the Facility and other parties responsible for delivery and reception of dangerous substances at the facility, and how safe conditions for operation are achieved and maintained. This includes safety systems to ensure that process conditions for the safe handing of dangerous substances are not exceeded. Examples include transfer of natural gas from transmission or distribution pipelines, and the loading or unloading of road or rail tankers.
C.4.5
Management of Contractors The use and management of contractors is included to show how risks at the facility arising from the use of third parties for work at the facility are controlled. The control measures of interest include: the selection of appropriate contractors for work at the facility; the setting and establishment of performance standards; the processes used for education and induction of contractors; the methods used to monitor and measure contractor safety performance, and the actions taken to ensure or improve overall performance; the recording of contractor performance data for use in future selection processes; and
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the identification of long-term contractors and specific arrangements made for their control.
C.4.6
Human Factors The Safety Management System should describe how the transmission undertaking addresses the human factors that are important to the management and safe operation of the facility and managing the response to emergencies. In particular, the Safety Management System should include processes for: identifying safety critical roles, responsibilities and tasks at all levels in the organisation, including management, operational staff and contractors; identifying the role specific competencies (behavioural and technical knowledge) and capabilities (skills and task specific) that are required to ensure the safe management of the flow of gas and the response to emergencies; selecting, recruiting, training, assessing and re-assessing staff and contractors; demonstrating that there is adequate availability of competent personnel (including contractors) for the safe management of the facility and the response to emergencies; demonstrating that adequate supervision of personnel in safety critical roles is provided, and that a satisfactory teamworking culture is maintained; demonstrating that procedures associated with operations are developed to take into account human factors, are maintained as current and are used in practice; and demonstrating that control room and human-machine interface (HMI) design are satisfactory, and that staff fatigue issues have been addressed especially where shift working is involved.
There is inevitably some overlap with other topics within the Guidelines, and it is satisfactory to discuss human factors elsewhere within a safety case.
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C.4.7
Consultation, Communication and Cooperation The Safety Management System should describe the systems in place for involving staff, either directly or through their representatives, in the development and implementation of the Safety Management System, and for consulting with staff and their representatives generally on issues relating to safety. The Safety Management System should describe the processes for the communication of safety information both internally and externally to the organisation and cooperation with external bodies with respect to gas safety. This should include a description of the processes for the communication of safety information: upwards and downwards within the undertaking; to and from other gas market participants; to and from other utilities, local authorities, construction industry and other third parties with respect to the protection of plant; to and from the Commission; and to and from end-use customers and the general public.
The Safety Management System should also describe the cooperative arrangements that exist between the undertaking and other external bodies that have interests in gas safety issues. For example these external bodies include: C.4.8 architects, building design consultants and developers; installation contractors; gas consumer representative bodies; Health and Safety Authority; Emergency Services; National Standards Authority for Ireland; and Government departments and other public and institutional bodies.
Documentation, Data and Records Management The Safety Management System should describe the documentation, data and records management systems that relate to asset and operational safety performance, including: the type and extent of asset and operational data to be collected; the mechanisms that are used to collect, analyse, interpret and record the data; how asset and operational documentation and data is made available to those authorised persons requiring access to the data; how changes to documentation, data and records are communicated to the relevant staff; and how obsolete documents, data and information are removed from points of issue and use.
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The Safety Management System should also describe the IT systems, databases and any other means of recording asset and operational safety performance data and how the data is protected, updated, retrieved, backed-up and archived. C.4.9 Change Management The Safety Management System should describe the systems and procedures implemented to ensure that the risks arising from changes to the storage undertaking are assessed and properly controlled both during the change process and after its completion. Examples of such changes include: significant changes to process plant or storage systems containing dangerous substances; major organisational changes that impact key safety related roles and responsibilities; changes to operating policies and procedures; and outsourcing of key activities.
The Safety Management System should also contain procedures for analyzing proposed changes through the Formal Safety Risk Assessment process. Where a change is deemed by the undertaking to be material, the Commission should be notified in accordance with the guidance on Safety Case Modifications as explained in Section A of these Guidelines. C.4.10 Accident and Incident Investigation The Safety Management System should provide evidence of appropriate arrangements for investigating gas safety related accidents and incidents, which should show that sufficient skill will be applied to ascertain not only the immediate cause(s) but also the root cause of such accidents and incidents. The arrangements for carrying out accident and incident investigation should also describe how recommendations to prevent recurrence are made and how follow-up actions are managed. C.4.11 Safety Reporting The Safety Management System should provide details of the safety reporting framework that the gas storage undertaking uses to demonstrate that gas safety is being managed effectively, that safety trends are analysed and progress towards safety performance objectives and targets are being achieved. The safety reporting framework should provide details of: the reporting regime for gas emergency incidents, a definition of the various categories of incident that may arise and the process and person interfaces involved in incident reporting and subsequent investigation; the structure and contents of the quarterly safety reports that the gas undertaking will be required to submit to the Commission. This
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should include a description and explanation of the safety key performance indicators (KPIs) that are used in measuring gas safety performance; and the structure and content of the annual safety report that the storage undertaking will be required to submit to the Commission. This should include a detailed description of the overall safety performance of the storage undertaking during the year and the actions that the undertaking proposes to take to improve gas safety.
C.4.12
Audit and Inspection The Safety Management System should describe the arrangements for safety audit and inspections as a continuing management and monitoring tool and the resources which will be applied to it. The audit and inspections regime should be based on the assessment of risk as it applies to the asset or activity under consideration. There should be a description of the approach to undertaking audit and inspection, which should include: the timing of routine audits and inspections daily, weekly, monthly, quarterly, annually or less frequent; the structure of audits and inspections activity v. process; and persons undertaking audits and inspections.
There should be a description of how the results of audits and inspections are fed back into the performance monitoring and review process. C.4.13 Performance Monitoring and Review The Safety Management System should describe how the storage undertaking reviews and assesses the safety performance of its assets and operations and should include the following: the approach to setting safety performance objectives and targets and the details of the intended frequency of monitoring progress towards the targets and who will be directly involved in reviewing the results; the methodology used to process data in order to monitor trends and progress towards safety performance objectives and targets and identification of the resources used to undertake such data processing and analysis; the process for determining whether the safety performance objectives and targets have been achieved and how the extent of any safety performance gaps are assessed; and the process for making recommendations on the corrective actions to be taken, approving the proposed corrective actions and monitoring outcomes for the results of corrective actions.
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C.4.14
Continual Improvement The Safety Management System should provide a description of the procedures for the regular and ongoing re-evaluation of the Safety Management System and the initiation of any necessary improvements. The inputs to this process should include the outcomes of the actions taken under the following: 4.10 4.11 4.12 4.13 Accident and Incident Investigation; Safety Reporting; Audit and Inspection; and Performance Monitoring and Review.
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C.5
Emergency Procedures
The Emergency Procedures section should describe in detail how the gas storage undertaking identifies and responds to emergencies involving dangerous substances. The emergencies considered must relate to the dangerous substances identified earlier, and must have sufficient flexibility to cater for all scales of emergency. Typical topics include: identification of appropriate emergency scenarios involving dangerous substances at the facility; the general responses to emergencies for the various dangerous substances at the facility; the identification and declaration of an emergency; the structure of the emergency management team that will coordinate the overall response to the emergency incident, and the means of communication employed between the various participants during an emergency including neighbouring third parties; the individual persons that will undertake the emergency management roles required of a gas storage undertaking, including arrangements for ensuring continuous cover of these roles where required; the contact details of the personnel on the emergency standby rota; the required actions of non-essential personnel at the facility in the event of a major accident; the resources (personnel and facilities) that will be employed in providing an effective emergency response; arrangements in place to ensure that equipment involved in emergency response has appropriate survivability to carry out its function on demand; the locations or buildings that have a role in emergency response (e.g emergency control centres, muster or rendezvous points); the arrangements in place for cleanup and restoration of the facility and the surrounding environment if required; the training that is given to ensure that emergency response roles can be fulfilled safely and competently; the frequency of testing of the emergency response capability that the undertaking carries out in order to assure itself that an effective emergency response can be provided both during and out of normal working hours;
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notification of the general public and other relevant third parties around the facility who should take appropriate action in the event of an emergency at the facility; and consultation and exchange of information with the emergency services, the local authority and any other third party involved in the emergency response.
C.5.1
Gas Quality Incidents The Emergency Procedures should also describe how the Operator establishes and maintains procedures to minimise risk in the event that the composition of the gas received by the network is outside the specified safe limits. The Operator should establish a control system to ensure that gas of inappropriate quality is not received from natural gas suppliers.
C.5.2
Specific Requirements for Lower Tier Facilities For lower tier gas storage facilities, the magnitude of the hazards are less but may still present high risk to persons and the environment depending on their location. Operators of such facilities will submit a safety case with the format as described above, but the risk analysis performed as part of the development of the safety case will indicate the extent to which the operator must complete the remaining sections. For example, a gas storage vessel in a remote area could present relatively low risk, but the same vessel next to a shopping centre could present relatively high risk. A greater degree of risk management is expected of the latter; however both cases need to show that authoritative best practice has been adopted for risk management. The description of the Major Accident Prevention Policy and the safety management needs to be equally detailed in all cases.
PART D: SPECIFIC REQUIREMENTS TRANSMISSION UNDERTAKINGS FOR GAS
Part D Specific Requirements for Gas Transmission Undertakings
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PART D SPECIFIC REQUIREMENTS UNDERTAKINGS
FOR
GAS
TRANSMISSION
This section of the Guidelines contains the specific minimum information requirements for the development of the safety case for gas transmission undertakings. These are minimum information requirements and it is the responsibility of the relevant undertaking to provide sufficient information in order to allow the Commission to make an assessment of the adequacy of the safety case. A balance will need to be struck between the material to be included in the safety case and supporting information, which can be crossreferenced and provided on request. As a guiding principle, safety cases should be presented as self-contained documents which: present the main safety arguments clearly and succinctly so that the core principles can be readily understood; and include sufficient detail to establishing a convincing case for the safety arrangements.
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D.0
Executive Summary
An Executive Summary, which explains the transmission undertakings approach to risk management, describes the generic gas safety risks that arise from the gas transmission operations and a description of the structure of the safety case to demonstrate that there are comprehensive safety management systems in place to identify, assess, manage and control the risks associated with the safe management of the flow and quality of gas and the response to emergencies.
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D.1.
Introduction
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D.2
The Facility Description should provide information on the following aspects of the undertakings operation: 2.1. 2.2. 2.3 The name of the person and position who has overall managerial responsibility for the gas transmission business; The geographic area covered by the transmission business and the downstream assets supplied; The location of the undertakings headquarters or main office, the location of subsidiary offices and a description of the activities undertaken at each location; A management organisation structure for the gas transmission business that describes how the management of gas safety is undertaken, who has responsibilities for gas safety, the numbers of personnel employed in each department/function and the key safety interfaces with operational staff; A description of the activities undertaken with the gas transmission business, how these are organized and the resources employed to manage the operations of the business; and A description of how gas is transported throughout the transmission network including details of: o gas entry points to the transmission network from gas suppliers, including inputs from other networks, subsea pipelines, gas terminals, LNG terminals and gas storage installations; o the various pressure tiers that are used to transmit gas throughout the geographic area; a description of the network assets that includes: the length, diameter, pipe specification & operating pressures of the transmission pipe system; the number and type of above-ground installations and compressor stations in the transmission network; the various categories and numbers of meters installed for custody transfer.
2.4
2.5
2.6
Suitable maps, drawings, tables, charts and diagrams should be used to convey information wherever appropriate. o a description of how gas flows and pressures in the transmission network are controlled and, where relevant, how gas blending is used to maintain gas quality within safe limits; and
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gas exit points to distribution networks or industrial consumers with direct connections to the transmission system
2.7
Details of the connected distribution systems and industrial installations with direct connections to the transmission system, and the identity of their owners and operators.
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D.3

The safety case should provide information on the processes adopted to systematically identify and assess all reasonably foreseeable hazards for gas incidents in order to determine the likelihood and consequence of the actual risks that they present to persons and property at each stage of the asset lifecycle i.e. design, construction, operation, maintenance, modification/refurbishment and de-commissioning. The descriptions should include the methods of any analyses made and details of any assumptions on asset and human performance and reliability. The level of detail required (including with respect to the sophistication of the risk assessment) should be proportional to the nature and complexity of the operations of a gas transmission undertaking and hence to the risks being controlled at a level that is as low as reasonably practicable (ALARP).
D.3.1
Hazard and Risk Identification and Assessment With respect to hazard identification, the transmission undertaking should identify all significant network hazards that arise from the operation of the whole transmission network, together with the initiating events that could lead to these hazards. The assessment must cover all assets, plant and equipment that could cause or contribute to a gas incident, including buried pipelines, above-ground installations and pipelines, compressor stations and subsea pipelines where present. An assessment should made of all the identified hazards in order to determine the likelihood and consequences of the risks that may arise. The assessment may be carried out using qualitative and/or quantitative techniques as considered appropriate by the transmission undertaking. The results of the hazard and risk assessments should be used to identify and rank major risk contributors. Risk management strategies should include prevention, protection and mitigation activities and risk reduction strategies should be established for all significant risks.
D.3.2
Recording of Risks The results of the hazard and risk identification and assessment process should be recorded in a suitably formatted risk register that record details of: identified hazards and their causes (initiating events); existing safety controls that are used to manage the risk; an assessment of the risk based on the likelihood and consequence of the risk occurring and tolerability of the risk according to the principle of ALARP; a description of any additional control measures that are required to reduce the risk to ALARP; a revised assessment of risk based on the implementation of the additional control measures to demonstrate ALARP; and the name of the person who is responsible for the day-to-day management of the risk(s).
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D.3.3
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D.4

The Safety Management System should describe how the Operator of the gas transmission undertaking provides for the safe and reliable flow of gas within the transmission network for the duration of the lifecycle of these assets. The essential elements of the Safety Management System are outlined below.
D.4.1
Safety Management Policy The Safety Management System should reference the specific Safety Policy documents published by the transmission undertaking that set out the safety management objectives with regard to the safe management of the gas transmission network. This section should describe the approach and methodology used to ensure that the gas transmission system is designed, constructed and operated and maintained in a safe manner and how this will be achieved. There should be a clear statement of the undertakings intention to implement the Safety Policy regarding the prevention of risk and the protection from hazards to all persons who may be affected by its activities and how the undertaking proposes to meet its safety objectives. The policy documents must be endorsed by a responsible person with sufficient authority to ensure that all safety-related commitments within these documents are met.
D.4.2
Technical Standards The Safety Management System should contain a list of all relevant Irish, European and other international codes, standards and recommendations (referred to collectively as authoritative best practice) that are used by the transmission undertaking for the design, construction and operation, modification and maintenance of the transmission system. These should include a list of updated current technical standards and legacy or historical technical standards used for the design and construction of existing assets. It is important that the transmission undertaking has a system for assuring itself that the technical standards and specifications currently being used are the latest version. As such, the Safety Management System should describe the process for ensuring that all amendments and new editions are recorded and an up to date list of standards is maintained and published.
D.4.3
Asset Lifecycle Safety 4.3.1 Design The Safety Management System should describe in detail the design principles applied to ensure that all identified hazards and risks are eliminated or reduced to a level as low as reasonably practicable during the life cycle of the network assets. The design requirements should include both the physical assets
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and the associated monitoring and control systems for the network. 4.3.1.1 Design Inputs Key inputs to the design process should include: o a list of identified design hazards and risks; o a statement of the transmission network design policy; o a description of the system design parameters for all network assets e.g. pipelines, services, aboveground installations and compressor stations; and o identification of the various codes, standards and recommendations adopted. 4.3.1.2 Design Process Controls Controls over the design process should include a description of: o the policies and procedures used for network design; o the risk mitigating measures adopted; o the systems and tools used for network design and modeling, including safety studies such as Hazard and Operability (HAZOP) studies, and studies to establish performance standards for safety related equipment; and o the design validation and approval process. 4.3.1.3 Design Outputs The outputs from the design should include: o construction plans and specifications; o performance standards, both in terms of risks and operational performance; and o specific operational procedures required for safe operation. 4.3.2 Construction, Testing & Commissioning and Work Recording The Safety Management System should describe in detail how the Operator manages the processes of network construction (includes pipeline replacement, reinforcement and alterations/diversions), testing and commissioning in accordance with the adopted codes, standards and specifications. The Operator should provide demonstration of the processes for: o ensuring that construction activities are undertaken by staff and/or contractors who possess the requisite qualifications, training, skills & experience and competencies to undertake the work in a safe manner; o assessing and verifying that the construction work undertaken complies with the specifications;
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ensuring that post-construction and precommissioning testing is undertaken in a safe and competent manner and is sufficient to prove that the installed asset is suitable for its intended use; ensuring that assets are commissioned as per an agreed procedure; and as-laid records are submitted, checked for accuracy and completeness and approved prior to being recorded on the companys asset database.
4.3.3
Operation and Maintenance The Safety Management System should describe in detail how the Operator undertakes the operation and maintenance of the network assets taking into account the particular risks posed by the asset under consideration. This should also extend to the associated systems that are in place to support the operation and maintenance of the assets e.g. drawings, plans, maintenance records, DCS or SCADA systems, permitry etc. The Operator should provide demonstration of the arrangements in place and processes for undertaking the following activities by asset group i.e. pipelines, AGI's and compressors - wherever possible:
4.3.3.1 Preventative Maintenance, which includes such activities as: o third party damage prevention; o leakage survey vehicle and foot patrol surveys; o pressure monitoring; o gas quality monitoring (e.g. CV, Wobbe number, water/hydrocarbon dewpoint, oxygen, sulphur compounds and other relevant compounds as necessary); o ground movement surveys; o cathodic protection monitoring; o maintenance of safety instrumented systems and other safety related protective or control systems; o non-routine operations procedures; and o permit-to-work systems. 4.3.3.2 Corrective Maintenance, which includes such activities as: o attending local incidents involving the transmission system, including reports of potential damage or pipeline contact, and adjacent incidents where pipeline safety may be an issue; o responding to gas system operating pressure related incidents i.e. low pressure or high pressure in the network; and o other asset-related emergency maintenance that may be required to be undertaken as identified in the Formal Safety Risk Assessment.
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4.3.3.3 Supporting Systems Maintenance, which includes such activities as: o storing and updating asset records i.e. drawings, plans, databases etc; and o maintenance of DCS or SCADA systems. 4.3.4 Modification, Replacement and Reinforcement The Safety Management System should describe in detail the processes that the Operator uses for undertaking network modifications, replacements and reinforcements including the processes for: o identifying the need for modification, replacement or reinforcement; o developing, designing and selecting the chosen approach to modification, replacement or reinforcement; o approving the selected design; and o updating asset records. De-Commissioning and Abandonment The Safety Management System should describe in detail the processes that the Operator uses for de-commissioning and abandoning transmission assets including: o identifying the need for de-commissioning and abandonment of an asset; o assessing the impact of the decision to decommission and abandon an asset; and o recording of de-commissioned and abandoned assets on the companys asset database.
4.3.5
D.4.4
New Connections The Safety Management System should provide a description of the control processes in place for ensuring that new connections to the transmission system, downstream distribution assets and other offtakes are installed in accordance with relevant Irish Standards before natural gas is supplied to them.
D.4.5
Connected Systems The Safety Management System should provide a description of the control processes for the connection of third party systems or connections to the Operators network. This should include a description of the processes for: assessing and approving third party designs; ensuring that all construction, testing and commissioning is undertaken in accordance with the design specifications; managing the interface (pressures, flows and gas quality) between the connected system and the Operators network; and
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managing emergencies on connected systems where emergency response arrangements have been agreed between the relevant System Operators or Asset Owners.
D.4.6
Procurement The Safety Management System should provide a description of the controls which will be applied to ensure that contractual arrangements entered into with third parties give appropriate assurance of safety. In particular, to ensure that no person is exposed to unacceptable risk from the actions and services or from the equipment and products provided to the transmission undertaking by external providers. The controls should include processes for: undertaking pre-contract checks on competency of personnel and conformity of products and equipment with relevant standards and specifications; assessing the overall safety management systems of the provider; and arrangements for monitoring of compliance with agreed safety standards.
D.4.7
Human Factors The Safety Management System should describe how the transmission undertaking addresses the human factors that are important to the management of the safe flow of gas and managing the response to gas emergency incidents. In particular, the Safety Management System should include processes for: identifying safety critical roles, responsibilities and tasks at all levels in the organisation, including management, operational staff and contractors; identifying the role specific competencies and capabilities that are required to ensure the safe management of the flow of gas and the response to emergencies; selecting & recruiting, training, assessing and re-assessing staff and contractors; demonstrating that there is adequate availability of competent personnel (including contractors) for the safe management of the flow of gas and the response to emergencies; demonstrating that adequate supervision of personnel in safety critical roles is provided, and that a satisfactory teamworking culture is maintained; demonstrating that procedures associated with operations are developed to take into account human factors, are maintained as current and are used in practice; and
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demonstrating that control room and human-machine interface (HMI) design are satisfactory, and that staff fatigue issues have been addressed especially where shift working is involved.
D.4.8
Consultation, Communication and Cooperation The Safety Management System should describe the systems in place for involving staff, either directly or through their representatives, in the development and implementation of the Safety Management System, and for consulting with staff and their representatives generally on issues relating to safety. A description of the processes for the communication of safety information both internally and externally to the organisation and cooperation with external bodies with respect to gas safety should be provided. This should include a description of the processes for the communication of safety information: upwards and downwards within the undertaking; to and from other gas market participants; to and from other utilities, local authorities, construction industry and other third parties with respect to the protection of plant; to and from the Commission; and to and from end-use customers and the general public.
The Safety Management System should also describe the cooperative arrangements that exist between the undertaking and other external bodies that have interests in gas safety issues. For example these external bodies include: D.4.9 architects, building design consultants and developers; installation contractors; gas consumer representative bodies; Health and Safety Authority; Emergency services; National Standards Authority for Ireland; and Government departments and other public and institutional bodies.
Documentation, Data and Records Management The Safety Management System should describe the documentation, data and records management systems that relate to asset and operational safety performance, including: the type and extent of asset and operational data to be collected; the mechanisms that are used to collect, analyse, interpret and record the data; how asset and operational documentation and data is made available to those authorized persons requiring access to the data;
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how changes to documentation, data and records are communicated to the relevant staff; and how obsolete documents, data and information are removed from points of issue and use.
The Safety Management System should also describe the IT systems, databases and any other means of recording asset and operational safety performance data and how the data is protected, updated, retrieved, backed-up and archived. D.4.10 Change Management The Safety Management System should describe the systems and procedures implemented to ensure that the risks arising from changes to the transmission undertaking are assessed and properly controlled both during the change process and after its completion. Examples of such changes include: significant changes to the configuration of the network or the way in which the network is supplied with gas; major organisational changes that impact key safety related roles and responsibilities; changes to operating policies and procedures; and outsourcing of key activities.
The Safety Management System should also contain procedures for analyzing proposed changes through the Formal Safety Risk Assessment process. Where a change is deemed by the undertaking to be material, the Commission should be notified in accordance with the guidance on Safety Case Modifications as explained in Section A of these Guidelines. D.4.11 Accident and Incident Investigation The Safety Management System should provide evidence of appropriate arrangements for investigating gas safety related accidents and incidents, which should show that sufficient skill will be applied to ascertain not only the immediate cause(s) but also the root cause of such accidents and incidents. The arrangements for carrying out accident and incident investigation should also describe how recommendations to prevent recurrence are made and how follow-up actions are managed. D.4.12 Gas Safety Promotion and Public Awareness The Safety Management System should provide a description of how the transmission undertaking promotes gas safety to raise public awareness of the potential dangers of gas. This will include for example: advertising the national gas emergency number; advising on the actions to be taken in the event of a suspected gas leak;
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implementing dial-before-you-dig schemes and protecting underground gas plant from the activities of third parties; and issuing advice on safe working in the vicinity of underground gas plant.
D.4.13
Safety Reporting The Safety Management System should provide details of the safety reporting framework that the transmission undertaking uses to demonstrate that gas safety is being managed effectively, that safety trends are analysed and progress towards safety performance objectives and targets are being achieved. The safety reporting framework should provide details of: the reporting regime for gas emergency incidents, a definition of the various categories of incident that may arise and the process and person interfaces involved in incident reporting and subsequent investigation; the structure and contents of the quarterly safety reports that the gas undertaking will be required to submit to the Commission. This should include a description and explanation of the safety key performance indicators (KPIs) that are used in measuring gas safety performance; and the structure and content of the annual safety report that the undertaking will be required to submit to the Commission. This should include a detailed description of the overall safety performance of the transmission undertaking during the year and the actions that the undertaking proposes to take to improve gas safety.
D.4.14
Audit and Inspection The Safety Management System should describe the arrangements for safety audit and inspections as a continuing management and monitoring tool and the resources which will be applied to it. The audit and inspections regime should be based on the assessment of risk as it applies to the asset or activity under consideration. There should be a description of the approach to undertaking audit and inspection, which should include: the timing of routine audits and inspections daily, weekly, monthly, quarterly, annually; the structure of audits and inspections activity v. process; and persons undertaking audits and inspections.
There should be a description of how the results of audits and inspections are fed back into the performance monitoring and review process.
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D.4.15
Performance Monitoring and Review The Safety Management System should describe how the transmission undertaking reviews and assesses the safety performance of its assets and operations and should include the following: the approach to setting safety performance objectives and targets and the details of the intended frequency of monitoring progress towards the targets and who will be directly involved in reviewing the results; the methodology used to process data in order to monitor trends and progress towards safety performance objectives and targets and identification of the resources used to undertake such data processing and analysis; the process for determining whether the safety performance objectives and targets have been achieved and how the extent of any safety performance gaps are assessed; and the process for making recommendations on the corrective actions to be taken, approving the proposed corrective actions and monitoring outcomes for the results of corrective actions.
D.4.16
Continual Improvement The Safety Management System should provide a description of the procedures for the regular and ongoing re-evaluation of the Safety Management System and the initiation of any necessary improvements. The inputs to this process should include the outcomes of the actions taken under the following: 4.11 4.12 4.13 4.14 4.15 Accident and Incident Investigation; Gas Safety Promotion and Public Awareness; - Safety Reporting; Audit and Inspection; and Performance Monitoring and Review.
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D.5
The Emergency Procedures section should describe in detail how the Operator of the gas transmission undertaking will fulfill its duties and obligations as required by the Network Emergency Manager during any of the following gas supply emergency situations: insufficient gas supply into the network, which has resulted in, or could result in, loss of pressure in the Transmission Network; a local gas supply emergency, which has resulted in, or could result in, loss of pressure in a section of pipeline within the Transmission Network or Distribution Network; and a gas quality emergency (see Gas Quality Incidents below).
The actions required of the transmission undertaking are currently described in the Network Emergency Manager (NEM) Framework document as issued by Bord Gis ireann (BG). The Emergency Procedures should describe clearly the specific actions that the Operator of the transmission undertaking will perform at each step of the gas emergency situation and how, and by whom, these actions will be carried out. The various steps in the gas emergency process are as shown below: Step Step Step Step Step 1: 2: 3: 4: 5: Potential Emergency Emergency Declaration Firm Load Shedding Allocation of Gas and Isolation Restoration
The Emergency Procedures should also identify: the structure of the emergency management team that will coordinate the overall response to the gas emergency incident, and the means of communication employed between the various participants during an emergency; the individual persons that will undertake the emergency management roles required of a gas transmission undertaking; the contact details of the personnel on the emergency standby rota; the training that is given to ensure that these roles can be fulfilled safely and competently; the resources (personnel and facilities) that will be employed in providing an effective emergency response; and the frequency of testing of the emergency response capability that the undertaking carries out in order to assure itself that an effective emergency response can be provided both during and out of normal working hours.
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D.5.1
Gas Quality Incidents The Emergency Procedures should also describe how the Operator establishes and maintains procedures to minimise risk in the event that the composition of the gas received by the network is outside the specified safe limits. The Operator should establish a control system to ensure that gas of inappropriate quality is not received from natural gas shippers.
PART E: SPECIFIC REQUIREMENTS DISTRIBUTION UNDERTAKINGS FOR GAS
Part E Specific Requirements for Gas Distribution Undertakings
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PART E SPECIFIC REQUIREMENTS UNDERTAKINGS
FOR
GAS
DISTRIBUTION
This section of the Guidelines contains the specific minimum information requirements for the development of the safety case for gas distribution undertakings. These are minimum information requirements and it is the responsibility of the relevant undertaking to provide sufficient information in order to allow the Commission to make an assessment of the adequacy of the safety case. A balance will need to be struck between the material to be included in the safety case and supporting information, which can be crossreferenced and provided on request. As a guiding principle, safety cases should be presented as self-contained documents which: present the main safety arguments clearly and succinctly so that the core principles can be readily understood; and include sufficient detail to establishing a convincing case for the safety arrangements.
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E.0
Executive Summary
An Executive Summary, which explains the distribution undertakings approach to risk management, describes the generic gas safety risks that arise from the gas distribution operations and a description of the structure of the safety case to demonstrate that there are comprehensive safety management systems in place to identify, assess, manage and control the risks associated with the safe management of the flow of gas and the response to emergencies.
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E.1.
Introduction
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E.2
The Facility Description should provide information on the following aspects of the undertakings operation: 2.1. 2.2. 2.3 The name of the person and position who has overall managerial responsibility for the gas distribution business; The geographic area covered by the distribution business and the numbers and categories of customers supplied; The location of the undertakings headquarters or main office, the location of subsidiary offices and a description of the activities undertaken at each location; A management organisation structure for the gas distribution business that describes how the management of gas safety is undertaken, who has responsibilities for gas safety, the numbers of personnel employed in each department/function and the key safety interfaces with operational staff; A description of the activities undertaken with the gas distribution business, how these are organized and the resources employed to manage the operations of the business; and A description of how gas is transported distribution network including details of: o throughout the
2.4
2.5
2.6
gas entry points to the distribution network from the higher pressure transmission system; the various pressure tiers that are used to distribute gas throughout the geographic area; a description of the network assets that includes: the length, diameter, pipe materials & operating pressures of the distribution pipe system; the number and type of pressure reducing installations in the distribution network; and the various categories and high level numbers of meters installed;
suitable maps, drawings, tables, charts and diagrams should be used to convey information wherever appropriate. o 2.7 a description of how gas flows and pressures in the distribution network are controlled
Details of any connected distribution systems and the identity of the connected network owners and operators.
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E.3

The safety case should provide information on the processes adopted to systematically identify and assess all reasonably foreseeable hazards for gas incidents in order to determine the likelihood and consequence of the actual risks that they present to persons and property at each stage of the asset lifecycle i.e. design, construction, operation & maintenance, modification/refurbishment and de-commissioning. The descriptions should include the methods of any analyses made and details of any assumptions on asset and human performance and reliability. The level of detail required (including with respect to the sophistication of the risk assessment) should be proportional to the nature and complexity of the operations of a gas distribution undertaking and hence to the risks being controlled at a level that is as low as reasonably practicable (ALARP).
E.3.1
Hazard and Risk Identification and Assessment With respect to hazard identification, the distribution undertaking should identify all significant network hazards that arise from the operation of the distribution network. An assessment should made of all the identified hazards in order to determine the likelihood and consequences of the risks that may arise. The assessment may be carried out using qualitative and/or quantitative techniques as considered appropriate by the distribution undertaking. The results of the hazard and risk assessments should be used to identify and rank major risk contributors. Risk management strategies should include prevention, protection and mitigation activities and risk reduction strategies should be established for all significant risks.
E.3.2
Recording of Risks The results of the hazard and risk identification and assessment process should be recorded in a suitably formatted risk register that record details of: identified hazards and initiating events and their causes; existing safety controls that are used to manage the risk; an assessment of the risk based on the likelihood and consequence of the risk occurring and tolerability of the risk according to the principle of ALARP; a description of any additional control measures that are required to reduce the risk to ALARP; a revised assessment of risk based on the implementation of the additional control measures to demonstrate ALARP; and the name of the person who is responsible for the day-to-day management of the risk(s).
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E.3.3
Monitoring and Review of Hazards and Risks There should be a description of the processes used to ensure that any new risks are identified and that existing risks are regularly reviewed to ensure that they are still valid, have not altered in terms of likelihood and/or consequence and are not outdated or redundant as a result of changes in organisational or operational circumstances.
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E.4

The Safety Management System should describe, at a minimum, how the Operator of the gas distribution undertaking provides for the safe and reliable flow of gas within the distribution network for the duration of the lifecycle of these assets. The essential elements of the Safety Management System are outlined below.
E.4.1
Safety Management Policy The Safety Management System should reference the specific Safety Policy documents published by the distribution undertaking that set out the safety management objectives with regard to the safe management of the gas distribution network. This section should describe the approach and methodology used to ensure that the gas distribution system is designed, constructed and operated and maintained in a safe manner and how this will be achieved. There should be a clear statement of the undertakings intention to implement the Safety Policy regarding the prevention of risk and the protection from hazards to all persons who may be affected by its activities and how the undertaking proposes to meet its safety objectives. The policy documents must be endorsed by a responsible person with sufficient authority to ensure that all safety-related commitments within these documents are met.
E.4.2
Technical Standards The Safety Management System should contain a list of all relevant Irish, European and other international codes, standards and recommendations (referred to collectively as authoritative best practice) that are used by the distribution undertaking for the design, construction, operation and maintenance, modification and decommissioning of the distribution system. These should include a list of updated current technical standards and legacy or historical technical standards used for the design and construction of existing assets. It is important that the distribution undertaking has a system for assuring itself that the technical standards and specifications that are currently being used are the latest version. As such, the Safety Management System should describe the process for ensuring that all amendments and new editions are recorded and an up to date list of standards is maintained and published.
E.4.3
Asset Lifecycle Safety 4.3.1 Design The Safety Management System should describe in detail the design principles applied to ensure that all identified hazards and risks are eliminated or reduced to a level as low as reasonably practicable during the life cycle of the network assets. The design requirements should include both the physical assets
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and the associated monitoring and control systems for the network. 4.3.1.1 Design Inputs Key inputs to the design process should include: o a list of identified design hazards and risks; o a statement of the distribution network design policy; o a description of the system design parameters for all network assets e.g. mains, services, pressurereducing installations and meters; and o identification of the various codes, standards and recommendations adopted. 4.3.1.2 Design Process Controls Controls over the design process should include a description of: o the policies and procedures used for network design; o the risk mitigating measures adopted; o the systems and tools used for network design and modeling; and o the design validation and approval process. 4.3.1.3 Design Outputs The outputs from the design should include: o construction plans and specifications; o performance standards, both in terms of risks and operational performance; and o specific operational procedures required for safe operation. 4.3.2 Construction, Testing & Commissioning and Work Recording The Safety Management System should describe in detail how the Operator manages the processes of network construction (includes mains replacement, reinforcement and alterations/diversions), testing and commissioning in accordance with the adopted codes, standards and specifications. The Operator should provide demonstration of the processes for: o ensuring that construction activities are undertaken by staff and/or contractors who possess the requisite qualifications, training, skills & experience and competencies to undertake the work in a safe manner; assessing and verifying that the construction work undertaken complies with the specifications; ensuring that post-construction and precommissioning testing is undertaken in a safe and competent manner and is sufficient to prove that the installed asset is suitable for its intended use; ensuring that assets are commissioned as per an agreed procedure; and
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as-laid records are submitted, checked for accuracy and completeness and approved prior to being recorded on the companys asset database.
4.3.3
Operation and Maintenance The Safety Management System should describe in detail how the Operator undertakes the operation and maintenance of the network assets taking into account the particular risks posed by the asset under consideration. This should also extend to the associated systems that are in place to support the operation and maintenance of the assets e.g. drawings, plans, maintenance records, DCS or SCADA systems, permitry etc.. The Operator should provide demonstration of the arrangements in place and processes for undertaking the following activities by asset group i.e. mains, services, district regulating installations (DRI), meters - wherever possible:
4.3.3.1 Preventative Maintenance, which includes such activities as: o third party damage prevention; o leakage survey vehicle and foot patrol surveys; o pressure monitoring; o gas quality monitoring (CV and odorant); o ground movement surveys; o cathodic protection monitoring; o DRI maintenance pneumatic and E&I control system maintenance; o I&C meter maintenance (including customers downstream equipment); o non-routine operations procedures; and o permit-to-work systems. 4.3.3.2 Corrective Maintenance, which includes such activities as: o attending public reported escapes (PREs) both inside and outside the property, including 3rd party damages, reports of no gas, and fires, explosions, CO incidents etc; o responding to gas system operating pressure related incidents i.e. low pressure or high pressure in the network; and o other asset-related emergency maintenance that may be required to be undertaken as identified in the Formal Safety Risk Assessment. 4.3.3.3 Supporting Systems Maintenance, which includes such activities as: o storing and updating asset records i.e. drawings, plans, databases etc; and o maintenance of DCS or SCADA systems. The Safety Management System should describe how the Operator undertakes both gas leakage and gas pressure management
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through the systematic monitoring of leakage trends and pressures within the network and the measures that are used to achieve: (i) an ongoing reduction in gas leakage from the network; and (ii) reliable security of gas supply. 4.3.4 Modification, Replacement and Reinforcement The Safety Management System should describe in detail the processes that the Operator uses for undertaking network modifications, replacements and reinforcements including the processes for: o identifying the need for modification, replacement or reinforcement; o developing, designing and selecting the chosen approach to modification, replacement or reinforcement; o approving the selected design; and o updating asset records. De-Commissioning and Abandonment The Safety Management System should describe in detail the processes that the Operator uses for de-commissioning and abandoning distribution assets including: o identifying the need for de-commissioning and abandonment of an asset; o assessing the impact of the decision to decommission and abandon an asset; and o recording of de-commissioned and abandoned assets on the companys asset database.
4.3.5
E.4.4
New Connections and Re-connections The Safety Management System should provide a description of the control processes in place for ensuring that customers downstream (of the meter) installations are installed in accordance with relevant Irish Standards before natural gas is supplied, or re-supplied, to the premises.
E.4.5
Connected Systems The Safety Management System should provide a description of the control processes for the connection of third party systems or connections to the Operators network. This should include a description of the processes for: assessing and approving third party designs; ensuring that all construction, testing and commissioning is undertaken in accordance with the design specifications; managing the interface (pressures and flows) between the connected system and the Operators network; and managing emergencies on connected systems where emergency response arrangements have been agreed between the relevant System Operators or Asset Owners.
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E.4.6
Procurement The Safety Management System should provide a description of the controls which will be applied to ensure that contractual arrangements entered into with third parties give appropriate assurance of safety. In particular, to ensure that no person is exposed to unacceptable risk from the actions and services or from the equipment and products provided to the distribution undertaking by external providers. The controls should include processes for: undertaking pre-contract checks on competency of personnel and conformity of products and equipment with relevant standards and specifications; assessing the overall safety management systems of the provider; and arrangements for monitoring of compliance with agreed safety standards.
E.4.7
Human Factors The Safety Management System should describe how the distribution undertaking addresses the human factors that are important to the management of the safe flow of gas and managing the response to gas emergency incidents. In particular, the Safety Management System should include processes for: identifying safety critical roles, responsibilities and tasks at all levels in the organisation, including management, operational staff and contractors; identifying the role specific competencies and capabilities that are required to ensure the safe management of the flow of gas and the response to emergencies; selecting, recruiting, training, assessing and re-assessing staff and contractors; demonstrating that there is adequate availability of competent personnel (including contractors) for the safe management of the flow of gas and the response to emergencies; demonstrating that adequate supervision of personnel in safety critical roles is provided, and that a satisfactory teamworking culture is maintained; and demonstrating that control room and human-machine interface (HMI) design is satisfactory and that staff fatigue issues have been addressed, especially where shift working is involved.
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E.4.8
Consultation, Communication and Cooperation The Safety Management System should describe the systems in place for involving staff, either directly or through their representatives, in the development and implementation of the Safety Management System, and for consulting with staff and their representatives generally on issues relating to safety. A description of the processes for the communication of safety information both internally and externally to the organisation and cooperation with external bodies with respect to gas safety should be provided. This should include a description of the processes for the communication of safety information: upwards and downwards within the undertaking; to and from other gas market participants; to and from other utilities, local authorities, construction industry and other third parties with respect to the protection of plant; to and from the Commission; and to and from end-use customers and the general public.
The Safety Management System should also describe the cooperative arrangements that exist between the undertaking and other external bodies that have interests in gas safety issues. For example these external bodies include: E.4.9 architects, building design consultants and developers; installation contractors; gas consumer representative bodies Health and Safety Authority; National Standards Authority for Ireland; and Government departments and other public and institutional bodies.
Documentation, Data and Records Management The Safety Management System should describe the documentation, data and records management systems that relate to asset and operational safety performance, including: the type and extent of asset and operational data to be collected; the mechanisms that are used to collect, analyse, interpret and record the data; how asset and operational documentation and data is made available to those authorized persons requiring access to the data; how changes to documentation, data and records are communicated to the relevant staff; and how obsolete documents, data and information are removed from points of issue and use.
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The Safety Management System should also describe the IT systems, databases and any other means of recording asset and operational safety performance data and how the data is protected, updated, retrieved, backed-up and archived. E.4.10 Change Management The Safety Management System should describe the systems and procedures implemented to ensure that the risks arising from changes to the distribution undertaking are assessed and properly controlled both during the change process and after its completion. Examples of such changes include: significant changes to the configuration of the network or the way in which the network is supplied with gas; major organisational changes that impact key safety related roles and responsibilities; changes to operating policies and procedures; and outsourcing of key activities.
The Safety Management System should also contain procedures for analyzing proposed changes through the Formal Safety Risk Assessment process. Where a change is deemed by the undertaking to be material, the Commission should be notified in accordance with the guidance on Safety Case Modifications as explained in Section A of these Guidelines. E.4.11 Accident and Incident Investigation The Safety Management System should provide evidence of appropriate arrangements for investigating gas safety related accidents and incidents, which should show that sufficient skill will be applied to ascertain not only the immediate cause(s) but also the root cause of such accidents and incidents. The arrangements for carrying out accident and incident investigation should also describe how recommendations to prevent recurrence are made and how follow-up actions are managed. E.4.12 Gas Safety Promotion and Public Awareness The Safety Management System should provide a description of how the distribution undertaking promotes gas safety to raise public awareness of the potential dangers of gas. This will include for example: advertising the national gas emergency number; advising on the actions to be taken in the event of a suspected gas leak; implementing dial-before-you-dig schemes and protecting underground gas plant from the activities of third parties; and issuing advice on safe working in the vicinity of underground gas plant.
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E.4.13
Safety Reporting The Safety Management System should provide details of the safety reporting framework that the distribution undertaking uses to demonstrate that gas safety is being managed effectively, that safety trends are analysed and progress towards safety performance objectives and targets are being achieved. The safety reporting framework should provide details of: the reporting regime for gas emergency incidents, a definition of the various categories of incident that may arise and the process and person interfaces involved in incident reporting and subsequent investigation; the structure and contents of the quarterly safety reports that the gas undertaking will be required to submit to the Commission. This should include a description and explanation of the safety key performance indicators (KPIs) that are used in measuring gas safety performance; and the structure and content of the annual safety report that the gas undertaking will be required to submit to the Commission. This should include a detailed description of the overall safety performance of the distribution undertaking during the year and the actions that the undertaking proposes to take to improve gas safety.
E.4.14
Audit and Inspection The Safety Management System should describe the arrangements for safety audit and inspections as a continuing management and monitoring tool and the resources which will be applied to it. The audit and inspections regime should be based on the assessment of risk as it applies to the asset or activity under consideration. There should be a description of the approach to undertaking audit and inspection, which should include: the timing of routine audits and inspections daily, weekly, monthly, quarterly, annually; the structure of audits and inspections activity v. process; and persons undertaking audits and inspections.
There should be a description of how the results of audits and inspections are fed back into the performance monitoring and review process. E.4.15 Performance Monitoring and Review The Safety Management System should describe how the distribution undertaking reviews and assesses the safety performance of its assets and operations and should include the following: the approach to setting safety performance objectives and targets and the details of the intended frequency of monitoring progress towards the targets and who will be directly involved in reviewing the results;
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the methodology used to process data in order to monitor trends and progress towards safety performance objectives and targets and identification of the resources used to undertake such data processing and analysis; the process for determining whether the safety performance objectives and targets have been achieved and how the extent of any safety performance gaps are assessed; and the process for making recommendations on the corrective actions to be taken, approving the proposed corrective actions and monitoring outcomes for the results of corrective actions.
E.4.16
Continual Improvement The Safety Management System should provide a description of the procedures for the regular and ongoing re-evaluation of the Safety Management System and the initiation of any necessary improvements. The inputs to this process should include the outcomes of the actions taken under the following: 4.11 4.12 4.13 4.14 4.15 Accident and Incident Investigation; Gas Safety Promotion and Public Awareness; Gas Safety Reporting; Audit and Inspection; and Performance Monitoring and Review.
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E.5
The Emergency Procedures section should describe in detail how the Operator of the gas distribution undertaking will fulfill its duties and obligations as required by the Network Emergency Manager during any of the following gas supply emergency situations: insufficient gas supply into the network, which has resulted in, or could result in, loss of pressure in the Transmission Network; a local gas supply emergency, which has resulted in, or could result in, loss of pressure in a section of pipeline within the Transmission Network or Distribution Network; and a gas quality emergency (see Gas Quality Incidents below).
The actions required of the distribution undertaking are described in the Network Emergency Manager (NEM) Framework document. The Emergency Procedures should describe clearly the actions that the Operator will undertake at each step of the gas emergency situation and how, and by whom, these actions will be carried out. The various steps in the gas emergency process are as shown below: Step Step Step Step Step 1: 2: 3: 4: 5: Potential Emergency Emergency Declaration Firm Load Shedding Allocation of Gas and Isolation Restoration
The Emergency Procedures should also identify: the structure of the emergency management team that will coordinate the response to the gas emergency incident; the individual persons that will undertake the emergency management roles required of a gas distribution undertaking; the contact details of the personnel on the emergency standby rota; the training that is given to ensure that these roles can be fulfilled safely and competently; the resources (personnel and facilities) that will be employed in providing an effective emergency response; and the frequency of testing of the emergency response capability that the undertaking carries out in order to assure itself that an effective emergency response can be provided both during and out of normal working hours.
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E.5.1
Gas Quality Incidents The Emergency Procedures should also describe how the Operator establishes and maintains procedures to minimise risk in the event that the composition of the gas distributed through the network is outside the specified safe limits. The Operator should establish a control system to ensure that the gas is not supplied to unsuitable appliances and installations.
PART F: SPECIFIC REQUIREMENTS FOR GAS SUPPLY & SHIPPER UNDERTAKINGS
Part E Specific Requirements for Supply and Shipper Undertakings
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PART F SPECIFIC REQUIREMENTS FOR GAS SUPPLY & SHIPPER UNDERTAKINGS

For the purposes of the efficient operation of the natural gas safety regulatory framework, there are two categories of supply and shipper undertakings to which the requirements for submitting a safety case applies, albeit to differing extents. These are: Category 1 - Supply & Shipper undertakings that procure, ship and supply gas to customers; and Category 2 Shipper-only undertakings that only participate in the procurement and shipping of gas to their own premises and do not supply gas to customers.
With respect to Category 1 - Supply and Shipper undertakings, the following are minimum information requirements and it is the responsibility of the relevant undertaking to provide sufficient information in order to allow the Commission to make an assessment of the adequacy of the safety case. A balance will need to be struck between the material to be included in the safety case and supporting information, which can be cross-referenced and provided on request. As a guiding principle, safety cases should be presented as self-contained documents which: present the main safety arguments clearly and succinctly so that the core principles can be readily understood; and include sufficient detail to establishing a convincing case for the safety arrangements.
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F.0
Executive Summary
An Executive Summary, which explains the supply & shipper undertakings approach to risk management, describes the generic gas safety risks that arise from the gas supply and shipping activities and a description of the structure of the safety case to demonstrate that there are comprehensive safety management systems in place to identify, assess, manage and control the risks associated with the safe management of the supply and shipping of gas and the response to emergencies.
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F.1
Introduction
76
F.2
The Facility Description should provide information on the following aspects of the undertakings operation: 2.1. 2.2. 2.3. The name of the person and position who has overall managerial responsibility for the gas supply & shipper business; The geographic area covered by the supply & shipper business and the categories (LDM, DM and NDM) of customers supplied; The location of the undertakings headquarters or main office, the location of subsidiary offices and a description of the activities undertaken at each location; A management organisation structure for the gas supply & shipper business that describes how the management of gas safety is undertaken, who has responsibilities for gas safety, the numbers of personnel employed in each department/function and the key safety interfaces with operational staff; and A description of the activities undertaken within the gas supply & shipper business, how these are organized and the resources employed to manage the operations of the business. Examples of such supply & shipper activities include: A: Procuring Gas o procuring supplies of gas to meet the required gas quality specifications; and o procuring sufficient quantity of gas to meet the undertakings aggregate customer demand. B: Shipping Gas o undertaking Unified Network Code functions either directly or indirectly via an agent e.g. demand forecasting, making nominations for injections and withdrawals, trading entry and exit point capacity, customer supply and demand balancing etc; o managing the day to day interface with gas transporters; and o responding to directions from the Network Emergency Manager (NEM) during gas supply emergency incidents. C: Supplying Gas o conducting sales and market development to secure sales of gas to new and existing customers; o developing and maintaining IT systems to enable billing of customers, collection of payments and the provision of customer support services; o providing energy efficiency and/or appliance installation advice to end-use customers;
2.4.
2.5.
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o o o
providing gas safety advice with respect to installation and servicing of appliances and what to do in the event of a suspected gas leak; offering gas appliance installation and maintenance services; maintaining a customer contact centre or bureau; and responding to directions from the Network Emergency Manager (NEM) during gas supply emergency incidents.
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F.3

The Formal Safety Risk Assessment should provide information on the processes adopted to systematically identify and assess all reasonably foreseeable hazards in order to determine the likelihood and consequence of the actual risks that they present to persons and property as a result of the gas supply & shipper activities described in the Facility Description. The descriptions should include the methods of any analyses made and details of any assumptions on asset (where applicable) and human performance and reliability. The level of detail required (including with respect to the sophistication of the risk assessment) should be proportionate to the nature and complexity of the operations of a gas supply and shipper undertaking and hence to the risks being controlled at a level that is as low as reasonably practicable (ALARP).
F.3.1
Hazard and Risk Identification and Assessment With respect to hazard identification, the supply and shipper undertaking should identify all significant gas safety hazards that arise from the operation of the undertaking. An assessment should be made of all the identified hazards in order to determine the likelihood and consequences of the risks that may arise. The assessment may be carried out using qualitative and/or quantitative techniques as considered appropriate by the supply & shipper undertaking. The results of the hazard and risk assessments should be used to identify and rank major risk contributors. Risk management strategies should include prevention, protection and mitigation activities and risk reduction strategies should be established for all significant risks.
F.3.2
Recording of Risks The results of the hazard and risk identification and assessment process should be recorded in a suitably formatted risk register that record details of: identified hazards and their causes; existing safety controls that are used to manage the risk; an assessment of the risk based on the likelihood and consequence of the risk occurring and acceptability of the risk according to the principle of ALARP; a description of any additional control measures that are required to reduce the risk to ALARP; a revised assessment of risk based on the implementation of the additional control measures and its acceptability; and the name of the person who is responsible for the day-to-day management of the risk(s).
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F.3.3
80
F.4

The Safety Management System should provide information on the following aspects of the undertakings operation:
F.4.1
Safety Management Policy The Safety Management System should reference the specific Safety Policy documents that set out the safety management objectives with regard to the safe management of the supply & shipping of gas to end use customers. There should be a clear statement of the undertakings intention to implement the Safety Policy regarding the prevention of risk and the protection from hazards to all persons who may be affected by its activities and how the undertaking proposes to meet its safety objectives.
F.4.2
Technical Standards The Safety Management System should contain a list of all relevant Irish, European and other international codes, standards and recommendations (referred to collectively as authoritative best practice) that are used by the undertaking for the supply & shipping of gas to end customers. It is important that the supply & shipper undertaking has a system for assuring itself that the technical standards and specifications currently being used are the latest version. As such, the Safety Management System should describe the process for ensuring that all amendments and new editions are recorded and an up to date list of standards is maintained and published.
F.4.3
Procurement The Safety Management System should provide a description of the controls which will be applied to ensure that contractual arrangements entered into with third parties give appropriate assurance of safety. In particular, to ensure that no person is exposed to unacceptable risk from the actions and services or from the equipment and products provided to the supply & shipper undertaking by external providers. The controls should include processes for: undertaking pre-contract checks on competency of personnel and conformity of products and equipment with relevant standards and specifications; assessing the overall safety management systems of the provider; and arrangements for monitoring of compliance with agreed safety standards.
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F.4.4
Human Factors The Safety Management System should describe how the supply & shipper undertaking addresses the human factors that are important to the management of the supply & shipping of gas. In particular, the Safety Management System should include processes for: identifying safety critical roles, responsibilities and tasks at all levels in the organisation, including management, operational staff and contractors; identifying the role specific competencies and capabilities that are required to ensure the safe management of the supply & shipping of gas; selecting & recruiting, training, assessing and re-assessing staff and contractors; and demonstrating that there is adequate availability of competent personnel (including contractors) for the safe management of the supply & shipping of gas.
F.4.5
Communication The Safety Management System should describe the processes for the communication of gas safety information both internally and externally to the organisation. This should include a description of the processes for the communication of safety information: upwards and downwards within the undertaking; to and from the Commission; and to and from end-use customers and the general public.
There should also be a description of the process for the passing of gas safety related reports and information to the gas transporter when received by the supply & shipper undertaking. For example, if a member of the public contacts the supply & shipping undertaking to report a smell of gas, there should be a robust process in place for passing of such information to the gas transporter who will provide the emergency response service. F.4.6 Change Management The Safety Management System should describe the systems and procedures implemented to ensure that the risks arising from changes to the supply & shipper undertaking are assessed and properly controlled both during the change process and after its completion. Examples of such changes include: major organisational changes that impact key safety related roles and responsibilities; changes to operating policies and procedures; and outsourcing of key activities.
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The Safety Management System should also contain procedures for analyzing proposed changes through the Formal Safety Risk Assessment process. Where a change is deemed by the undertaking to be material, the Commission should be notified in accordance with the guidance on Safety Case Modifications as explained earlier in these Guidelines. F.4.7 Customer Gas Safety Awareness The Safety Management System should describe how the supply & shipper undertaking supports and promotes customer gas safety awareness to its end use customers. There should be clear demonstration of how supply & shipper undertakings: establish and maintain systems for communicating information to consumers regarding the safety of gas installations and appliances; provide published material with information and adequate warnings about the potentially hazardous properties of gas, in particular the dangers of carbon monoxide, and the national emergency contact telephone number for reporting gas escapes; inform customers about the correct action with respect to defects or malfunctions of gas installations and appliances and the means by which consumers can report those defects or malfunctions; state the approval scheme for gas appliances and the manner in which a consumer can determine whether or not a gas appliance has been approved; inform consumers that persons undertaking gas fitting work are required to be a registered gas installer and the manner in which consumers can determine whether a person is appropriately licensed or registered; and provide additional safety support measures to vulnerable or infirm consumers.
F.4.8
Safety Reporting The Safety Management System should provide details of the safety reporting framework that the supply & shipper undertaking uses to monitor the effectiveness of its Customer Safety Awareness measures as described in 4.7 above. This should include: the number and category of reports emergencies and/or unsafe situations; and received regarding gas
the structure and contents of the quarterly and annual safety reports that the gas supply & shipper undertaking will be required to submit to the Commission, which describes the implementation and effectiveness of its Customer Gas Safety Awareness measures.
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F.4.9
Audit and Inspection The Safety Management System should describe the arrangements for safety audit and inspections as a continuing management and monitoring tool and the resources which will be applied to it. The audit and inspections regime should be based on the assessment of risk as it applies to the activity under consideration. There should be a description of the approach to undertaking audit and inspection, which should include: the timing of routine audits and inspections; the structure of audits and inspections activity v. process; and persons undertaking audits and inspections.
There should be a description of how the results of audits and inspections are fed back into the performance monitoring and review process. F.4.10 Performance Monitoring and Review The Safety Management System should describe how the supply & shipper undertaking monitors and reviews the implementation of the safety policies, objectives, procedures and performance standards specified in the Safety Management System, for example: the approach to setting Customer Gas Safety Awareness objectives and targets and the details of the intended frequency of monitoring progress towards the targets and who will be directly involved in reviewing the results; the methodology used to process data in order to monitor trends and progress towards safety performance objectives and targets and identification of the resources used to undertake such data processing and analysis; the process for determining whether the Customer Gas Safety Awareness performance objectives and targets are being achieved; and the process for making recommendations on the corrective actions to be taken, approving the proposed corrective actions and monitoring outcomes for the results of corrective actions.
F.4.11
Continual Improvement The Safety Management System should provide a description of the procedures for the regular and ongoing re-evaluation of the Safety Management System and the initiation of any necessary improvements.
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F.5
The Emergency Procedures section should describe in detail how the gas supply & shipper undertaking will fulfill its duties and obligations as required by the Network Emergency Manager during any of the following gas supply emergency situations: insufficient gas supply into the network, which has resulted in, or could result in, loss of pressure in the Transmission Network; a local gas supply emergency, which has resulted in, or could result in, loss of pressure in a section of pipeline within the Transmission Network or Distribution Network; and a gas quality emergency (see Gas Quality Incidents below).
The actions required of the supply & shipper undertaking is described in the Network Emergency Manager (NEM) Framework document as issued by Bord Gis ireann (BG). The Emergency Procedures should describe clearly the actions that the supply & shipper will undertake at each step of the gas emergency situation and how, and by whom, these actions will be carried out. The various steps in the gas emergency process are as shown below: Step Step Step Step Step 1: 2: 3: 4: 5: Potential Emergency Emergency Declaration Firm Load Shedding Allocation of Gas and Isolation Restoration
The Emergency Procedures should also identify: the structure of the emergency management team that will coordinate the response to the gas emergency incident; the individual persons that will undertake the emergency management roles required of a supply & shipper undertaking; the contact details of the personnel on the emergency standby roster; the training that is given to ensure that these roles can be fulfilled safely and competently; the resources (personnel and facilities) that will be employed in providing an effective emergency response; and the frequency of testing of the emergency response capability that the supply & shipper undertaking carries out in order to assure itself that an effective emergency response can be provided both during and out of normal working hours.
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F.5.1
Gas Quality Incidents The Emergency Procedures should also describe how the supply & shipper undertaking notifies and advises its end use customers in the event that the composition of the gas distributed through the network is outside the specified safe limits.
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F.6.
Requirements For Shipper-Only Undertakings

For Category 2 - Shipper-only undertakings i.e. those undertakings that procure and ship gas to their own premises only and do not retail gas to customers there is a reduced safety case requirement and the following information should be provided: a description of the facility (or facilities) to which gas is being shipped and the end-use process(es) for which natural gas is being used; details of the formal safety risk assessment undertaken for the procurement and shipping of gas; the in-house procedures and arrangements employed for the safe utilisation of gas within the facility or facilities; and the contact name(s) and telephone/fax numbers of persons who are to be contacted in the event of a network gas supply emergency and details of the arrangements in place for complying with the requirements of the Network Emergency Manager.
Any shipper-only undertakings that wish to commence the supply of gas to end use customers should notify the Commission in advance and will be required to submit a revised safety case, as for supply & shipper undertakings, prior to supplying gas to end use customers.
Appendix 1 Technical Specifications
87
APPENDIX 1 - TECHNICAL SPECIFICATIONS

The following list of relevant technical specifications as proposed by the National Standards Authority for Ireland (NSAI) is considered suitable and relevant to the activities falling within the scope of this document. This list contains undated references. The user is expected to use the latest version together with all amendments and corrections if any. It should be noted that the list is not exhaustive and there may be other specifications relevant to the scope. 1. I.S. 265 : Parts 1 and 2 Installation of Gas Service Pipes. 2. I.S. 328 : Code of Practice for Gas Transmission Pipelines and Pipeline Installations 3. I.S. 329 : Gas distribution mains 4. I.S. EN 331: Manually operated ball valves and closed bottom taper plug valves for gas installations for buildings 5. I.S. EN 334: Gas pressure regulators for inlet pressures up to 100 bar 6. I.S./EN 549: Rubber Materials for Seals and Diaphragms for Gas Appliances and Gas Equipment 7. I.S. EN 682: Elastomeric seals - Materials requirements for seals used in pipes and fittings carrying gas and hydrocarbon fluids 8. I.S./EN 751-1: Sealing materials for metallic threaded joints in contact with 1st, 2nd and 3rd family gases and hot water - Part 1: Anaerobic jointing compounds 9. I.S./EN 751-2: Sealing materials for metallic threaded joints in contact with 1st, 2nd and 3rd family gases and hot water - Part 2: Non-hardening jointing compounds 10. I.S./EN 751-3: Sealing materials for metallic threaded joints in contact with 1st, 2nd and 3rd family gases and hot water - Part 3: Unsintered PTFE tapes 11. I.S. 808 : Specification for CNG Fuelled Vehicles
Appendix 1 Technical Standards
88
12. I.S. 813: Domestic gas installations 13. I.S. 820: Non-domestic gas installations 14. I.S./EN 1057: Copper and copper alloys - seamless, round copper tubes for water and gas in sanitary and heating applications 15. I.S. EN 1106: Manually operated taps for gas burning appliances 16. I.S./EN 1160: Installations and equipment for liquefied natural gas - General characteristics of liquefied natural gas 17. I.S. EN 1359: Gas meters - Diaphragm gas meters 18. I.S. EN 1473: Installation and equipment for liquefied natural gas Design of onshore installations 19. I.S. EN 1474: Installation and equipment for liquefied natural gas Design and testing of loading/unloading arms 20. I.S. EN 1532: Installation and equipment for liquefied natural gas Ship to shore interface 21. I.S. EN 1555-1: Plastics piping systems for gaseous fuels supply - Polyethylene (PE) General 22. I.S. EN 1555-2: Plastics piping systems for gaseous fuels supply - Polyethylene (PE) Pipes 23. I.S. EN 1555-3: Plastics piping systems for gaseous fuels supply - Polyethylene (PE) Fittings 24. I.S. EN 1555-4: Plastics piping systems for gaseous fuels supply - Polyethylene (PE) Valves 25. I.S. EN 1555-5: Plastics piping systems for gaseous fuels supply - Polyethylene (PE) Fitness of purpose of the system
89
26. I.S. EN 1594: Gas supply systems - Pipelines for maximum operating pressure over 16 bar - Functional requirements 27. I.S. EN 1643: Valve proving systems for automatic shut-off valves for gas burners and gas appliances 28. I.S. EN 1775: Gas supply - Gas pipework for buildings - Maximum operating pressure less than or equal to 5 bar - Functional recommendations 29. I.S. EN 1776: Gas supply systems - Natural gas measuring stations - Functional requirements 30. I.S. EN 1918-1: Gas supply systems - Underground gas storage Part 1: Functional recommendations for storage in aquifers 31. I.S. EN 1918-2: Gas supply systems - Underground gas storage Part 2: Functional recommendations for storage in oil and gas fields 32. I.S. EN 1918-3: Gas supply systems - Underground gas storage Part 3: Functional recommendations for storage in solution-mined salt cavities 33. I.S. EN 1918-4: Gas supply systems - Underground gas storage Part 4: Functional recommendations for storage in rock caverns 34. I.S. EN 1918-5: Gas supply systems - Underground gas storage - Part 5: Functional recommendations for surface facilities 35. ISO 4437: Buried polyethylene (PE) pipes for the supply of gaseous fuels -Metric series -- Specifications 36. I.S. EN ISO 6326-3: Natural gas - Determination of sulfur compounds - Determination of hydrogen sulfide, mercaptan sulfur, and carbonyl sulfide sulfur by potentiometry 37. I.S. EN ISO 6326-5: Natural gas Determination of sulfur compounds - Part 5: Lingener combustion method 38. I.S. EN ISO 6974-1: Natural gas - Determination of composition with defined uncertainty by gas chromatography - Part 1: Guidelines for tailored analysis
90
39. I.S. EN ISO 6974-2: Natural gas - Determination of composition with defined uncertainty by gas chromatography - Part 2: Measuring-system characteristics and statistics for processing of data 40. I.S. EN ISO 6974-3: Natural gas - Determination of composition with defined uncertainty by gas chromatography - Part 3: Determination of hydrogen, helium, oxygen, nitrogen, carbon dioxide and hydrocarbons up to C8 using two packed columns 41. I.S. EN ISO 6974-4: Natural gas - Determination of composition with defined uncertainty by gas chromatography - Part 4: determination of nitrogen, carbon dioxide and C1 to C5 and C6+ hydrocarbons for a laboratory and online measuring system using two columns 42. EN ISO 6974-5: Natural gas - Determination of composition with defined uncertainty by gas chromatography - Part 5: Determination of nitrogen, carbon dioxide and C1 to C5 and C6+ hydrocarbons for a laboratory and online process application using thee columns (ISO 6974- Describes a gas chromatographic method for the quantitative determination of natural gas constituents using a three-column system 43. I.S. EN ISO 10440-1: Petroleum and natural gas industries rotary-type positive displacement compressors Part 1: Process compressors (oil-free) 44. I.S. EN ISO 10440-2: Petroleum and natural gas industries - Rotary-type positivedisplacement compressors - Part 2: Packaged air compressors (oilfree) 45. I.S. EN ISO 10715: Natural gas - Sampling guidelines 46. I.S. EN ISO 10723: Natural gas - Performance evaluation for on-line analytical systems 47. I.S. EN 12007-1: Gas supply systems - Pipelines for maximum operating pressure up to and including 16 bar Part 1: General functional recommendations 48. I.S. EN 12007-2: Gas supply systems - Pipelines for maximum operating pressure up to and including 16 bar Part 2: Specific functional recommendations for polyethylene (MOP up to and including 10 bar) 49. I.S. EN 12007-3: Gas supply systems - Pipelines for maximum operating pressure up to and including 16 bar Part 3: Specific functional recommendations for steel
91
50. I.S. EN 12007-4: Gas supply systems - Pipelines for maximum operating pressure up to and including 16 bar Part 4: Specific functional recommendations for renovation. 51. I.S. EN 12186: Gas supply systems - Gas pressure regulating stations for transmission and distribution - Functional requirements ( 52. I.S. EN 12261: Gas meters - Turbine gas meters 53. I.S. EN 12279: Gas supply systems - Gas pressure regulating installation on service lines - Functional requirements 54. I.S. EN 12308: Installations and equipment for LNG - Suitability testing of gaskets designed for flanged joints used on LNG piping 55. I.S. EN 12327: Gas supply systems - Pressure testing, commissioning and decommissioning procedures - Functional requirements 56. I.S. EN 12405-1: Gas meters - Part 1: Volume conversion 57. I.S. EN 12480: Gas meters - Rotary displacement gas meters 58. I.S. EN 12583: Gas supply systems - Compressor stations - Functional requirements 59. I.S. EN 12567: Industrial valves - Isolating valves for LNG Specification for suitability and appropriate verification tests 60. I.S. EN 12669: Direct gas-fired hot air blowers for use in greenhouses and supplementary non-domestic space heating 61. I.S. EN 12732: Gas supply systems - Welding steel pipework Functional requirements 62. I.S. EN 12838: Installations and equipment for liquefied natural gas Suitability testing of LNG sampling systems 63. I.S. EN 13090: Means for resealing threaded joints of gas pipework in buildings 64. I.S. EN 13423: Compressed natural gas vehicle operations
92
65. I.S. EN ISO 13734: Natural gas - Organic sulphur compounds used as odorants Requirements and test methods 66. I.S. EN 13774: Valves for gas distribution systems with maximum operating pressure less than or equal to 16 bar - Performance requirements 67. I.S. EN 13787: Elastomers for gas pressure regulators and associated safety devices for inlet pressures up to 100 bar 68. I.S. EN 13942: Petroleum and natural gas industries Pipeline transportation systems Pipeline valves 69. I.S. EN ISO 14111: Natural gas - Guidelines to tractability in analysis 70. I.S. EN 14141: Valves for natural gas transportation in pipelines Performance requirements and tests 71. I.S. ENV 14236: Ultrasonic domestic gas meters 72. I.S. EN 14382: Safety devices for gas pressure regulating stations and installations Gas safety shut-off devices for operating pressure up to 100 bar
Appendix 2 Suggested Key Performance Indicators
93
APPENDIX 2 SUGGESTED KEY PERFORMANCE INDICATORS

No. 1 Key Objective Minimising the Risk of Loss of Containment Gas Safety Performance Indicator (SPI) 1.1. No. of public reported escapes: a) external; and b) internal 1.2. No. of 3rd party damages to: a) transmission pipelines b) distribution mains; and c) distribution services 1.3. No. of cast iron mains fractures 1.4. No. of joint leaks 1.5. No. of mains leak repairs/km 1.6. No. of outstanding leaks 1.7. Length of network leakage surveyed (kms) 1.8. Nos. of survey leaks/km 1.9. No. of gas in building events 1.10. No. of evacuations undertaken 1.11. Length of accelerated mains renewal achieved (kms) 1.12. No. of actionable transmission pipeline corrosion defects detected 2.1 No. of verified poor pressure complaints (transmission & distribution) 2.2 No. of over-pressure events (transmission & distribution) 2.3 No. of unplanned gas outages affecting: a) > 5 customers b) > 20 customers c) > 100 customers 3.1 No. of gas odorant checks undertaken 3.2 No. of non-compliant gas odorant samples found 3.3 No. and type of gas quality excursions detected 4.1 % of uncontrolled PREs attended within 1 hour 4.2 % of controlled PREs attended within [4] hours 4.3 No. of transmission system related gas supply emergencies attended 4.4 No. of distribution system related gas supply emergencies attended 4.5 No. of gas quality related gas supply emergencies 4.6 No. of emergency exercises undertaken 5.1 No. of residential completion certificates issued
Maintaining Safe System Operating Pressures
Minimising the Risk of Injecting Gas on NonConforming Quality Providing an Efficient and Coordinated Response to Gas Emergency Reports and Incidents
Minimising the Risks
Appendix 2 - Suggested Key Performance Indicators
94
Associated with the Utilisation of Gas
Promoting Public Awareness of Gas Safety
5.2 No. of residential installations inspected 5.3 Average number of defects per residential installation inspected 5.4 No. of non-residential completion certificates issued 5.5 No. of non-residential installations inspected 5.6 Average number of defects per non-residential installation inspected 5.7 No. of metering tampering events discovered 5.8 No. of internal gas related incidents attended: a) fires b) explosions c) CO related To be discussed with individual undertakings
Appendix 3 Requirements for Demonstrations
95
APPENDIX 3 - REQUIREMENTS FOR DEMONSTRATIONS

In its decision paper A Natural Gas Safety Regulatory Framework for Ireland (ref: CER/07/172), the Commission stated that: The emphasis of the Safety Case regime is on demonstration by the gas undertaking that acceptable safety arrangements for the management of gassafety related risks are in place and working effectively on a day-to-day basis. In this context, demonstration involves a higher standard than simply describing the way measures work or are expected to work. There will be a requirement on the undertaking to provide evidence that the measures described in the safety case work in practice and are monitored to ensure that this actually happens. The safety case contents describe the safety management systems that the undertaking has put in place to ensure that gas safety risks arising from the activities of the undertaking are controlled to a level that is considered by the undertaking to be as low as reasonably practicable. The safety management systems consist of various policies, procedures, processes, codes, recommendations, technical standards and specifications that are used by the undertaking to manage and control gas safety risks and these will be referenced in the safety case. However, it will not be acceptable to merely quote such documents within the safety case as evidence that safety management systems are based on robust management arrangements. There will be a requirement to provide evidence of: How the safety-related policies and procedures are effectively implemented within the undertaking and who has responsibility for implementation; What monitoring and control measures are in place to ensure that the safety-related policies and procedures are implemented effectively; How often policies and procedures are reviewed; How safety-related data is collected and stored what systems, databases are used; Who reviews safety-related data, how often and how does this inform decision-making as to what actions are required; Etc.
The Commission will seek evidence that the undertaking has made a robust case that the necessary safety measures are in place and that management has the ability to support and maintain the arrangements on an ongoing basis. The Commission recognises that there is a practical limit to the amount of information that can be logically presented in a safety case document. However, the safety case should be suitable cross-referenced (and hyper-linked where practical) to supporting internal company documents that collectively constitute the safety management system. There should also be references to the company IT systems and databases that are used for storing and analyzing safety-related data.
Appendix 3 Requirements for Demonstrations
96
The assessment of the undertakings safety case will include a detailed review of the both the safety case contents and the undertakings safety management systems as referenced in the safety case. This process will be described in more detail in the Safety Case Assessment Manual.

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Natural Gas Safety Regulatory Framework Safety Case Guidelines

CER/07/226 17th December 2007

E.4.13 E.4.14 E.4.15 E.4.16

PART A: GENERAL REQUIREMENTS UNDERTAKINGS SAFETY CASE FOR GAS

Part A General Requirements for Gas Undertakings Safety Cases

Part A General Requirements for Gas Undertakings Safety Cases

Safety Case Contents

Part A General Requirements for Gas Undertakings Safety Cases

Part A General Requirements for Gas Undertakings Safety Cases

Part A General Requirements for Gas Undertakings Safety Cases

Part A General Requirements for Gas Undertakings Safety Cases

Safety Case Reporting Framework

Part A General Requirements for Gas Undertakings Safety Cases

Safety Case Assessment

Part A General Requirements for Gas Undertakings Safety Cases

Part A General Requirements for Gas Undertakings Safety Cases

Safety Case Submission Process

Part A General Requirements for Gas Undertakings Safety Cases

Safety Case Modifications

Part A General Requirements for Gas Undertakings Safety Cases

Part A General Requirements for Gas Undertakings Safety Cases

PART B: SPECIFIC REQUIREMENTS FOR LNG UNDERTAKINGS

Part B Specific Requirements for LNG Undertakings

PART B SPECIFIC REQUIREMENTS FOR LNG UNDERTAKINGS

PART C: SPECIFIC REQUIREMENTS FOR GAS STORAGE UNDERTAKINGS

Part C Specific Requirements for Gas Storage Undertakings

PART C SPECIFIC REQUIREMENTS FOR GAS STORAGE UNDERTAKINGS

The safety case contents should include the following sections.

Part C Specific Requirements for Gas Storage Undertakings

Part C Specific Requirements for Gas Storage Undertakings

Part C Specific Requirements for Gas Storage Undertakings

Part C Specific Requirements for Gas Storage Undertakings

Part C Specific Requirements for Gas Storage Undertakings

Part C Specific Requirements for Gas Storage Undertakings

Formal Safety Risk Assessment

Part C Specific Requirements for Gas Storage Undertakings

Part C Specific Requirements for Gas Storage Undertakings

Safety Management System

Part C Specific Requirements for Gas Storage Undertakings

Part C Specific Requirements for Gas Storage Undertakings

Part C Specific Requirements for Gas Storage Undertakings

Part C Specific Requirements for Gas Storage Undertakings

Part C Specific Requirements for Gas Storage Undertakings

Part C Specific Requirements for Gas Storage Undertakings

Part C Specific Requirements for Gas Storage Undertakings

Part C Specific Requirements for Gas Storage Undertakings

Part C Specific Requirements for Gas Storage Undertakings

Part C Specific Requirements for Gas Storage Undertakings

PART D: SPECIFIC REQUIREMENTS TRANSMISSION UNDERTAKINGS FOR GAS

Part D Specific Requirements for Gas Transmission Undertakings

PART D SPECIFIC REQUIREMENTS UNDERTAKINGS

The safety case contents should include the following sections.

Part D Specific Requirements for Gas Transmission Undertakings

Part D Specific Requirements for Gas Transmission Undertakings

Part D Specific Requirements for Gas Transmission Undertakings

Part D Specific Requirements for Gas Transmission Undertakings

Part D Specific Requirements for Gas Transmission Undertakings

Formal Safety Risk Assessment

Part D Specific Requirements for Gas Transmission Undertakings

Part D Specific Requirements for Gas Transmission Undertakings

Safety Management System

Part D Specific Requirements for Gas Transmission Undertakings